1. Proposed Reasonable Progress Rule Workshop Second Public Workshop August 1, 2007 Tallahassee, Florida

2. Comments From 1 st Workshop Extend the permit application deadline (April 30, 2008, Dec 31, 2008) Extended to September 30, 2008 Change the compliance deadline date (Dec 31, 2017) Extended to December 31, 2014 Increase significant contribution threshold (1%) Considered, developed new criteria Allow consideration of visibility impact Changed rule language to reflect visibility impact analysis not required

3. Comments From 1 st Workshop (cont.) Take out the “responsibility to comply” applicability statement Retained – makes sense with new selection criteria Produce area of influence document Document no longer necessary with new selection criteria “Reasonable progress” already made, no additional reductions needed Reasonable progress only determined after four-factor analysis – state cannot bypass this requirement

4. Comments From 1 st Workshop (cont.) Provide justification for selection of various thresholds or cutpoints Provided at this workshop Change BART-equivalent determination submittal application deadline to coincide with the RP application Extended deadline to June 30, 2008 – still does not coincide with application

5. Jun 14 Proposed Selection Criteria Selection based on modified Georgia criteria with RTmax*Q/d: VISTAS residence time data (within 5% for EGU’s and 10% non-EGU’s) 2002 actual emissions (units > 250 tpy) >= 0.5% unit contribution, considering only Florida units Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

6. Considered Changes to Selection Based on Comments Increase contribution threshold from 0.5% to 1% Include units in all states to determine contribution Take out EGU/non-EGU selection criterion based on RTMax See handout for results

7. Considerations for Changing to a Q/d Selection Criteria The inclusion of residence time (RTMax), while logical, is somewhat complicated, and when used with Q/d to develop a relative contribution surrogate at each Class I area, results in some seemingly illogical conclusions. The use of Q/d alone as a surrogate for visibility impact is easy to understand and produces a similar selection of sources as does a Q/d*RTMax relative contribution criterion.

8. Proposed New Selection Criteria All SO2 units having >= 250 tpy (2002 actual) and having an emissions Q (tons) to distance d (km) ratio of 50 or greater. Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

9. Why Q/d >= 50? Selection of sources close to those under the 1% Q/d*RTMax criteria. Q/d of 50 is five times the exemption threshold used for BART. Provides that sources selected are important contributors to visibility impairment. Recognize that visibility improvement at the Class I areas in or near Florida is projected to be near the uniform rate of progress, thus justifying selection of only the largest sources for four-factor review.

10. Plant Name Point IDClass I Areas Affected CITY OF GAINESVILLE, GRU DEERHAVEN GENER5CHASOKEF FLORIDA POWER & LIGHT (PPE) PORT EVERGLA3EVER 4 PROGRESS ENERGY FLORIDA, INC. CRYSTAL RI1CHASOKEFSAMAWOLF 2CHASOKEFSAMAWOLF 3CHASEVEROKEFSAMAWOLF 4CHASEVEROKEFSAMAWOLF FLORIDA POWER & LIGHT (PTF) TURKEY POINT1EVER 2 SAINT JOHNS RIVER16CHASOKEFWOLF 17OKEFWOLF NORTHSIDE27OKEF 3 WOLF GULF POWER COMPANY CRIST ELECTRIC GENERA7BRETSAMA FLORIDA CRUSHED STONE CO., INC.18CHAS TAMPA ELECTRIC COMPANY F.J. GANNON STATI1CHAS 2 3 4 5 6 OKEFSAMA Sources Selected Under the Q/d Criteria

11. Plant Name Point IDClass I Areas Affected FLORIDA POWER & LIGHT (PMT) MANATEE POWE1CHAS 2 EVER JEFFERSON SMURFIT CORPORATION (US)15OKEF PROGRESS ENERGY FLORIDA, INC. ANCLOTE PO1CHASSAMA 2CHASSAMA PROGRESS ENERGY FLORIDA, INC. BARTOW PLA1CHAS 2 3 LAKELAND ELECTRIC C.D. MCINTOSH, JR. POW6CHAS SEMINOLE ELECTRIC COOPERATIVE, INC.1CHASOKEFWOLF 2CHASOKEFSAMAWOLF Sources Selected Under the Q/d Criteria

13. Comparison of Selection Criteria ProposalNo. of Facilities Selected No. of Units Selected June 14 Workshop 3069 Modifications to June 14 Workshop (1%) 2243 August 1 Workshop 1532

14. Some Statistics The 15 facilities included comprise ~ ⅔ of the total stationary point source SO2 emissions that occurred in 2002. In rank order, these 15 facilities comprise the 1,2,3,4,5,6,7,8,9,15,18,19,26, and 30 largest facilities in the state as of 2002.

15. Plant NamePoint IDType SO2 ALLOWABL E EMISSION ALLOWABLE EMISSION UNIT 2002 SO2 EMISSION (TON/YR) PERCENT CONTROL EFFICIENC Y PRIMARY CONTROL EQUIPMENT GRU DEERHAVEN5coal-fired boiler1.2lb/MMBtu6,969 Scrubber by 2010 FPL PORT EVER3oil/gas-fired boiler2.75lb/MMBtu6,409 4oil/gas-fired boiler2.75lb/MMBtu6,205 PE CRYSTAL RIVER1coal-fired boiler2.1lb/MMBtu18,998 2coal-fired boiler2.1lb/MMBtu20,728 3coal-fired boiler1.09lb/MMBtu26,436 Scrubber by 2010 4coal-fired boiler1.09lb/MMBtu24,635 Scrubber by 2010 FPL TURKEY POINT1oil/gas-fired boiler1.1lb/MMBtu4,610 2oil/gas-fired boiler1.1lb/MMBtu4,327 JEA ST JOHNS RIVER16coal-fired boiler1.2lb/MMBtu11,07690.0Scubber 17coal-fired boiler1.2lb/MMBtu10,18590.0Scubber JEA NORTHSIDE27coal-fired boiler0.2lb/MMBtu5,09098.0 DRY LIMESTONE INJECTION 3oil/gas-fired boiler1.98lb/MMBtu7,146 GULF POWER CRIST7coal-fired boiler2.75lb/MMBtu21,546 Scrubber by 2010 FL CRUSHED STONE18coal-fired boiler1.2lb/MMBtu2,90650.0 DRY LIMESTONE INJECTION

16. Plant NamePoint IDType SO2 ALLOWABL E EMISSION ALLOWABLE EMISSION UNIT 2002 SO2 EMISSION (TON/YR) PERCENT CONTROL EFFICIENC Y PRIMARY CONTROL EQUIPMENT TECO GANNON1coal-fired boiler3017lb/hr5,157 Shutdown 2coal-fired boiler1.9lb/MMBtu4,942 Shutdown 3coal-fired boiler3838lb/hr5,602 Shutdown 4coal-fired boiler4502lb/hr5,577 Shutdown 5coal-fired boiler5482lb/hr8,043 Shutdown 6coal-fired boiler9115lb/hr16,097 Shutdown FPL MANATEE1oil/gas-fired boiler1%S Fuel13,930 2oil/gas-fired boiler1%S Fuel15,073 SMURFIT STONE FB15coal-fired boiler1.2lb/MMBtu3,242 PE ANCLOTE1oil/gas-fired boiler2.75lb/MMBtu13,879 2oil/gas-fired boiler2.75lb/MMBtu13,225 PE BARTOW1oil/gas-fired boiler2.75lb/MMBtu6,483 Re-powering to gas 2oil/gas-fired boiler2.75lb/MMBtu6,149 Re-powering to gas 3oil/gas-fired boiler2.75lb/MMBtu11,249 Re-powering to gas LAKELAND MCINTOSH6coal-fired boiler1.2lb/MMBtu6,99485.0Scubber SEMINOLE ELECTRIC1coal-fired boiler1.2lb/MMBtu10,91290.0Scubber 2coal-fired boiler1.2lb/MMBtu12,77590.0Scubber