1 Brian Finneran, Oregon DEQ WRAP IWG Meeting, Portland August 2006 Suggested Changes to IWG Section 308 SIP Template

2 IWG 308 SIP TEMPLATE Outline of Most Recent Version 1. Introduction 2. Background and Regional Haze SIP Requirements – Historical and Statutory Overview  Visibility Provisions in 1977 Clean Air Act (CAA 169A)  EPA Visibility Protection Regulations  Clean Air Act Amendments of 1990  Current Long-Term Strategy  Code of Federal Regulations 308/ Regional Haze Rule 3. Regional Haze SIP Development Process  Federal Land Manager Consultation 4. Visibility Monitoring and Impairment in Class I Areas – Overview of IMPROVE monitoring program in Class I areas  Visibility Impairment Characteristics in Class I Areas 5. Visibility Impairment in Class I Areas  Natural Sources of Visibility Impairment  Anthropogenic Sources of Visibility Impairment

3 IWG 308 SIP TEMPLATE Outline 6. Establishing the plan baseline conditions – baseline and natural conditions, presumptive RPGs for 20% best/worst average days  Baseline Conditions  Natural Conditions  Establishing Presumptive Reasonable Progress Goals 7. Emission Inventory – 2002 Baseline & 2018 Projections  Regional Emission Inventories  Emission Inventories  Local Emission Inventories  Regional Modeling  Preliminary Assessment of Presumptive RP at Class I Areas 8. Best Available Retrofit Technology (or a superior alternative)  Description of BART Rule and Schedule  Visibility Improvement Resulting from BART in + Other States

4 IWG 308 SIP TEMPLATE Outline 9. Additional Measures (Long Term Strategy)  Emission Reductions Due to Ongoing Air Pollution Programs  Measures to Mitigate the Impacts of Construction Activities  Emission Limitations and Schedules of Compliance  Source Retirement and Replacement Schedules  Agricultural and forestry smoke management  Enforceability of emission limitations and control measures 10. Net Effects Resulting from Projected Emission Changes 11. Projection of 2018 Visibility Conditions from 2002 Base Case & Additional Strategies (BART & Others)  Affirmative Demonstration of Presumptive Reasonable Progress Goals 12. State and Tribe Consultation 13. Share of Emission Reductions Additional SIP Requirements & Future Planning Period Requirements List of Appendices and Technical Support Documentation (EDMS & TSS)

5 Oregon Suggested Format for 308 SIP TEMPLATE 1. Introduction 2. Oregon Regional Haze SIP Development Process 3. Introduction to Oregon Class I Areas 4. Regional Haze Monitoring 5. Visibility Sources and Conditions 6. Oregon Current Visibility Conditions 7.Oregon Visibility Impairment Analysis 8.Emission Inventory 9. Long-Term Strategy 10. Best Available Retrofit Technology (BART) Evaluation 11. Reasonable Progress Goal Demonstration 12. Misc. other SIP commitments

6 Chapter Comparison of IWG SIP TEMPLATE to Oregon Version 1. Introduction – short section 2.Background and RH SIP Requirements 3. RH SIP Development Process – FLM + state/tribe consultation 4. Visibility Monitoring and Impairment – IMPROVE monitoring – network description and 20% worst day monitoring data 1. Introduction – IWG #2 Background added here, and expanded 2. Oregon RH SIP Development Process - same as IWG #3, but added adv committee and public & stakeholder outreach 3. Introduction to Oregon Class I Areas – basic info on each Class I area (location, size etc) 4. Regional Haze Monitoring – no data here – just IMPROVE network description

7 5. Visibility Impairment – short section, generic definition of natural/anthro sources 6. Estimates of Baseline/Natural conditions, RPGs for 20% best/worst days Note: no in-depth analysis of Class I area haze conditions in IWG SIP Template 5. Visibility Sources and Conditions – same as IWG#5, but added defs of baseline, nat’l conditions, URP, and RPG 6. Oregon Current Visibility Conditions – review of all monitoring data showing current conditions 7. Oregon Visibility Impairment Analysis – Aerosol composition, species trends, monthly distribution, – similar to n draft CO SIP Chapter Comparison of IWG SIP TEMPLATE to Oregon Version

8 7. Emission Inventory – 2002 Baseline & 2018 Projections – local, state and regional EI, regional modeling results, and preliminary assessment of RP 8. BART (or a superior alternative) – results of BART analysis 9. Additional Measures (Long Term Strategy) – very short summary of LTS, no explanation of “additional measures” ?? 8. Emission Inventory – similar to IWG#7 + more EI data and maps similar to draft CO SIP section 9. Long-Term Strategy – similar to IWG #9, more description of LTS, adds summary of interstate transport and anthro sources (follows RHR Sec.308 language) 10. Best Available Retrofit Technology (BART) Evaluation – similar to IWG #8 Chapter Comparison of IWG SIP TEMPLATE to Oregon Version

9 10. Net Effects Resulting from Projected Emission Changes – short section on visibility benefits from emission changes in 2018 (??) 11. Projection of 2018 Visibility Conditions from 2002 Base Case & Additional Strategies (BART & Others) – very short, affirmative demonstration of RPGs 11. Reasonable Progress Goal Demonstration – major section – needs to show improvement from all RH haze strategies in comparison to the glide path, analysis if whether additional controls are needed, and affirmative demonstration of RPGs Chapter Comparison of IWG SIP TEMPLATE to Oregon Version

10 Oregon Version of 308 SIP TEMPLATE 1.Introduction History and Background of RHR, purpose of SIP, definitions  Overview of Visibility and Regional Haze  Oregon Class I Areas (list)  Summary of Section 308 and 309 of the Regional Haze Rule  Background on the Regional Haze Rule  Phase I Visibility Rules – the Oregon Visibility Protection Plan  The 1990 Clean Air Act Amendments  Submittal of the 2003 Oregon 309 SIP  Purpose of this Document  Definitions and Acronyms contained in this plan 2.Oregon Regional Haze SIP Development Process General description of the consultation process and public involvement  Federal Land Manager Consultation  State and Tribal Consultation  Advisory Committee Involvement  Public and Stakeholder Outreach

11 Oregon Version of 308 SIP TEMPLATE 3. Introduction to Oregon Class I Areas General introduction and description of each Class I area 4. Regional Haze Monitoring Description of monitoring strategy and summary of IMPROVE network  Overview of Oregon Regional Haze Monitoring Strategy  IMPROVE site locations in Oregon 5. Visibility Sources and Conditions Summary of basic elements of the SIP, review of key terminology.  Anthropogenic Sources of Visibility Impairment  Baseline Conditions  Natural Sources of Visibility Impairment  Natural Conditions  Uniform Rate of Progress  Reasonable Progress Goal

12 Oregon Version of 308 SIP TEMPLATE 6. Oregon Current Visibility Conditions Summary of monitoring data that shows current conditions 7. Oregon Visibility Impairment Analysis Summary of monitoring data that shows impairment – aerosol composition, species trends, presumptive GP, URP 8. Emission Inventory Summary of all emissions data  Regional Emission Maps  Oregon Emissions by Source Category  Local (Nearby) Emissions for Each Class I Area by Source Category  Comparison to the URP for 2018  Back Trajectory Maps

13 Oregon Version of 308 SIP TEMPLATE 9. Long-Term Strategy  Overview of the LTS  Summary of Interstate Transport and Contribution  Other State Class I Areas affected by Oregon emissions  Oregon Class I Areas affected by Other States  Estimated International Contribution to Oregon Class I Areas  Estimated Non-Anthropogenic Sources and their contribution to Oregon Class I Areas  Summary of all Anthropogenic Sources of Visibility Impairment considered in developing the LTS  Emission Reductions Due to Ongoing Air Pollution Programs  Measures to Mitigate the Impacts of Construction Activities  Source Retirement and Replacement Schedules  Agricultural and Forestry smoke management techniques  Emission Limitations and Schedules of Compliance  Net Effect on Visibility from the LTS  Emission Reductions from point, area, and mobile sources  Projection of 2018 Visibility Conditions from 2002 Base Case

14 Oregon Version of 308 SIP TEMPLATE 10. Best Available Retrofit Technology (BART) Evaluation Summary of BART process, modeling, and control evaluation results  Oregon BART-eligible sources  Summary of BART Modeling Results  Summary of BART Control Analysis  Visibility Improvement Resulting from BART Evaluation in Oregon and Other States 11. Reasonable Progress Goal Demonstration Comparison of all haze strategies (chapters 9 & 10) to glide path, analysis if add’l controls are needed & affirmative RFG demonstration  Projected 2018 Visibility Conditions - Base Case vs. Control Case Scenarios  Review of Visibility Improvement from combination of BART modeling and regional modeling results.  Weight of Evidence Analysis Summary for each Class I area  Comparison of RPG to the URP for each Class I area  Assessment if Additional Controls Measures are needed  Affirmative Demonstration of Reasonable Progress

15 Oregon Version of 308 SIP TEMPLATE 12. Consultation Similar to Chapter 2, but provides more info, such as consistency with other state SIPs and TIPs, details of consultation with FLMs  Other State Consultation  Consistency with Neighboring State SIPs  Oregon and Neighboring State Emission Reduction Obligations  Tribal Consultation  Federal Land Manager Consultation 13. Enforceability of Emission Limitations and Control Measures 14. Commitment to Future SIP Revisions 15. Commitment to Periodic Progress Reports 16. Determination of Plan Adequacy 17. Public Participation and Review Process 18. List of Appendices and Technical Support Documentation (EDMS & TSS)