1. Summary of RH-LTS Requirements 51.308(d)(3)
Presentation to the
WRAP Implementation Work Group
Denver, CO
August 30, 2007
Ray Mohr
Colo. Dept. Public Health & Environment

2. Long Term Strategy
Those portions of the Visibility SIP which are the state’s long-term (first planning period) strategies for making reasonable progress toward the National Goal established in the Clean Air Act by Congress by remedying existing and preventing future impairment in Class I areas.

3. Review and update of Phase I Visibility SIP
Long Term Strategy Submittal Closes the Loop – Coordination of Phase I and RH SIPs
Review and update of Phase I Visibility SIP
Regional Haze SIP addresses 308 (d) (and (e)) requirements

4. Phase I SIP Update and Revision
Included as Appendices to Colorado RH SIP
Addresses all Phase I requirements including RAVI and smoke management

5. Regional Haze LTS Requirements
Addresses Rule requirements (consultation, meets RP show and how the Rule factors were addressed
Addresses the seven factors relating to 308 Rule requirements including smoke management, construction and BART
Reasonable Progress Goal portion of LTS is a state-only component (the 7th factor) and will be addressed in later submittals

6. The 308 LTS Factors 1. Emission reductions from ongoing programs
2. Additional emission limitations and and compliance schedules
3. Source retirement and replacement schedules
4. Smoke management techniques
5. Measures to mitigate impacts from construction
6. Enforceability of emission limitations
7. Anticipated net effect of on visibility due to projected changes in emissions

7. Smoke Management Plan addresses open burning, prescribed fire, permitting and wildfire
1. See State Regulation No. 9 for detailed program description
2. See Colorado Natural Events Action Plan for Wildfire Smoke
3. Public information and advisories

8. Measures to mitigate impacts from Construction activities
1. Existing State Regulations Nos. 1 and 3 provide detailed program description
2. Emissions impact analysis indicates current control program is likely sufficient

10. Regional Haze SIP - Chapter Overview
Chapter 2 Plan Development and Consultation
Chapter 3 Monitoring Strategy
Chapter 4 Baseline and Natural Conditions and Uniform Progress for each Class I Area
Chapter 5 Sources of Impairment in Colorado
Chapter 6 Best Available Retrofit Technology
Chapter 7 Visibility Modeling and Apportionment
Chapter 8 Reasonable Progress Goals
Chapter 9 Long Term Strategy
Chapter 10 Commitment to Consultation, Progress Reports, Evaluations of Plan Adequacy and Future SIP Revisions
Chapter 11 Guidance, Resources and References: