1. Workshop Technical and Policy Studies to Support the Annex
May 21-22, 2002

2. Overview of Workshop
Background information about the regional haze rule and the Annex
Background information about SO2 in the West
Roll-out major studies to provide additional information about the Annex

3. Overview of Workshop Discussion of EPA proposed approval of the Annex
On-going work of the WRAP to support 309 option

4. Section 309 and Annex

5. 1999 Regional Haze Rule
The nine Transport Region states have the option to develop SIPs under section 308 or 309 of the rule
Adopted the GCVTC recommendations as section 309
Implementation of GCVTC recommen-dations is demonstration of reasonable progress

6. 1999 Regional Haze Rule 2003 SIPs - Stationary Source Requirements
Monitoring and reporting of stationary source SO2 emissions
Declining SO2 emissions cap
Criteria and procedures for backstop trading program
Provisions for activating backstop trading program and compliance reporting

7. 1999 Regional Haze Rule 2003 SIPs - Requirements for other sources
Mobile sources: Cap emissions at lowest level in areas that contribute significantly to visibility impairment
Fire: Enhanced smoke management programs
Area Sources: Emission management strategies for fugitive dust if necessary

8. 1999 Regional Haze Rule 2003 SIPs - Requirements for other sources
Pollution Prevention: Renewable energy goals
Other Recommendations as practicable
The entire package of emission reduction strategies is needed for a 309 SIP

9. 1999 Regional Haze rule Schedule (section 309)
Annex to GCVTC Recommendations due October 1, 2000
SIPs due December 31, 2003
No required submittal dates for TIPs
Periodic Reports in 2008, 2013
New SIP under section 308 due in 2018

10. Annex Submitted September 29, 2000
Developed through stakeholder, consensus-based process
Supplementary information to address EPA questions – May 2001
EPA proposed approval on May 6, 2002

11. Milestones - Principles
Achieve Steady Continuing Emissions Reductions
Provide Flexibility to Sources “Up-Front” for Greater “Back-End” Reductions
2018 Milestone Achieves Greater Reasonable Progress than BART

12. SO2 Milestones
13% Reduction
52% Reduction

13. Compliance Averaging and Banking
Compliance based on annual assessment of 3-year rolling average
2018 milestone compliance determined based on 2018 inventory (1 year)
Banking of early reductions allowed

14. Better Reasonable Progress Than BART
Provides remedy for existing and prevention of future impairment
More sources and total tonnage covered
New source growth capped for the region
Regional haze visibility improvement not distinguishable from application of BART

15. 2018 Certainty
Concern that the majority of emissions reductions occur in the time frame
States and tribes may trigger the cap-and-trade program if the 2013 milestone is achieved, but best projections show that the 2018 milestone may not be achieved
Penalties in 2018 if milestone is not met

16. Opt-in/Opt-out Procedures
Budget calculated for each state and tribe that has major sources of SO2
New source set-aside budget
Solely for purposes of adjusting the milestone
Set-aside will remain at regional level
Tribal allocation not affected
Critical Mass question

17. Allocations Set-asides Source Specific 20,000 tons for tribes
27,000 tons for new sources
Suspended smelters
California RECLAIM
Source Specific
Floor (BACT/BART/LAER)
Reducible
Renewables

18. Trading Program Elements
Model Rule defines:
Procedures
Duties of program administrator
Monitoring, record keeping and reporting
Compliance and enforcement
MOU among participating States and Tribes

19. Reasonably Attributable Visibility Impairment
Hot Spots – not regional haze
3-step process
Certification by FLM (screening process)
Attribution analysis by state/tribe
BART analysis (several remedy options proposed)

20. Workshop

21. Workshop Today 10:15 SO2 and sulfates in the west
11:00 Non-utility allocation estimates
2:00 EPA’s proposed Annex approval
4:15 Critical Mass

22. Workshop Tomorrow 8:15 Annex Visibility Modeling
10:30 Reasonable Attributable Visibility
Impairment
2:00 Overview of ongoing work of the
WRAP to support 309 SIPs/TIPs
(MTF, IOC, TOC)