308 Outline (a) Purpose (b) When are 1st plans due (c) Options for regional planning (d) Core requirements (e) BART requirements (f) Comprehensive periodic revisions (g) Periodic progress reports (h) Determination of adequacy (i) State/FLM coordination

(a) Purpose Establish requirements for implementation plans, plan revisions, and periodic progress reports

(b) When are 1st plans due? Attainment -- 1 yr after PM 2.5 designation Nonattainment -- 3 yrs after PM 2.5 designation Coordinates your PM 2.5 and haze SIP(s), but not haze SIPs across your state or the region Can only be revised by Congress

(c) Regional planning option Would allow you to defer most SIP requirements until last date at which a SIP in the region would be due under (b) This approach seriously questioned in American Corn Growers v. EPA For our purposes, we assume TEA-3 legislation will require all 308 haze SIPs to be due by end of 2007 Middle-of-the-road planning assumption. Not as long as 2008, but more than 3 years after designations.

(d) Core requirements Must address haze in each mandatory Class I Federal area in the state and each area outside the state which may be affected by emissions from within the state Must explicitly identify which areas each SIP addresses Low hurdle for selecting such areas Criteria not defined

(d)(1) RPGs (reasonable progress goals) For each area [singular] within your state, establish goals [plural] (in dv) that provide for RP towards achieving nautral conditions The goals must: Improve most impaired days Ensure no degradation in lease impaired days In establishing a goal, you must: Consider cost, time, energy/non-air quality impacts, and remaining useful life AND include a demo showing how these factors were taken into account in selecting the goal

(d)(1) RPGs (continued) Determine the uniform rate of progress Consider uniform ROP and measures needed to achieve it during period covered by SIP deciviews 20% Worst Baseline 20% Best Baseline Uniform ROP Goals Natural conditions

(d)(2) Calculations Baseline conditions (at least 3 years) Natural conditions EPA guidance or alternative appropriate technique

(d)(3) Long-term strategy Consult with downwind states you may be affecting Consult with upwind states that may be affecting you Where other states contribute, include all measures necessary to obtain your share of the emission reductions needed to meet the RPG Document the technical basis for determining your share of emission reduction obligations

(d)(3) Long-term strategy ID all sources of impairment considered Also consider (taken from 1980 rule): Ongoing air pollution programs Measures to mitigate impacts of construction Emission limitations and schedules for compliance to achieve the RPG Source retirement and replacement schedules Smoke management techniques for agriculture and forestry mangement, including existing plans in the state Enforceability Anticipated net effect on visibility

(d)(4) Monitoring strategy and other requirements Compliance may be met through participation in IMPROVE Establish any additional sites or equipment needed to assess RP ID procedures by which monitoring or other data are used in determining the contribution of emissions from your state to impairment in other states This is the only place where a contribution assessment is discussed Annual reporting of monitoring data Statewide emissions inventory (2002)

The rule does not appear to... dictate the length of the planning period require you to determine and report your contribution to impairment in another state require you to report your share of emission reduction obligations

2008 requirements for 309 Do 308(d) and (e) for areas other than the 16 on the Colorado Plateau, except for SO 2 BART If your state has one of the 16 areas, participate as a downwind state for those areas in other states’ 308 process Track emisssions Fire (including emission reduction techniques) SO 2 (for comparison to milestones) Clean air corridor Mobile sources Track AP2 progress

Tribal Issues Refine framework for tribal/federal implementation on tribal lands When is a FIP appropriate? What elements may be reasonably severable? ???