1. Proposed Reasonable Progress Rule Workshop Brief Background and Procedure Public Workshop June 14, 2007

2. Regulatory Requirements Clean Air Act – Sections 169A and B Federal Rules – Federal Register, Vol. 64, No. 126, Thursday, July 1, 1999 – “Regional Haze Rule” 40 CFR Part 51, Subpart P – Protection of Visibility Federal Guidance on Reasonable Progress Guidance for Setting Reasonable Progress Goals Under the Regional Haze Program, U.S. EPA, June 1, 2007, rev

3. National Goal ”Congress hereby declares as a national goal the prevention of any future, and the remedying of any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from manmade air pollution.” Achieve natural visibility conditions within Class I areas by 2064

4. Regional Haze Rule - Purpose Section 51.300 – “... require states to develop programs to assure reasonable progress toward meeting the national goal of preventing any future, and remedying any existing, impairment of visibility in mandatory Class I Federal areas which impairment results from manmade air pollution …”

5. RH Program Requirements State must submit an implementation plan (SIP) Must establish goals (expressed in deciviews) that provide for reasonable progress towards achieving natural visibility conditions

6. Concept

7. Four Factors in Determining the Reasonable Progress Goal Cost of compliance Time necessary for compliance Energy and non-air quality environmental impacts of compliance Remaining useful life of any potentially affected sources

8. Three Components to Consider Evaluation of 2018 visibility considering current or “on the books” requirements for emissions reductions (e.g., CAIR, motor vehicle emissions standards, and many other already commanded reductions). VISTAS has completed this component. Regional Haze Rule directed BART requirements, section 51.302. Not completed. Regional Haze Rule directed Reasonable Progress requirement, section 51.308. Subject of this rulemaking.

14. IPM Projections Converts all oil-fired boilers to gas Affects sources throughout the state, but largely in South Florida. Primary power company (FPL) has indicated no intention of gas-only operation. Result, projected glidepaths (esp. Everglades) overly optimistic.

15. Plant NamePoint ID 2002 Actual SO2 Emissio ns (TPY) 2018 VISTAS Projected SO2 Emissions (TPY) FLORIDA POWER & LIGHT (PPE) PORT EVERGLA13,0530 23,2840 36,4090 46,2050 FLORIDA POWER & LIGHT (PTF) TURKEY POINT14,3270 24,6100 FLORIDA POWER & LIGHT (PMT) MANATEE POWE113,9300 215,0730 FLORIDA POWER & LIGHT (PMR) FPL / MARTIN16,8860 27,6030 FLORIDA POWER & LIGHT (PRV) RIVIERA POWE34,6300 44,2910 PROGRESS ENERGY FLORIDA, INC. ANCLOTE PO113,8790 213,2250 PROGRESS ENERGY FLORIDA, INC. BARTOW PLA16,1490 26,4830 311,2490 NORTHSIDE37,1460 PROGRESS ENERGY FLORIDA, INC. FL POWER S16570 28090 37400

16. Applicability of Reasonable Progress Applies to all sources and all visibility- impairing pollutants. Purpose of this rule is to use the information derived from VISTAS to target the most relevant sources (i.e., pair-down the number of sources and pollutants needed to evaluate for reasonable progress).

17. Important Results from VISTAS Sulfate is the dominate component of regional haze in the Southeast. Implication – focus on SO2 reductions Nearly all of the SO2 emissions are from coal and oil-fired EGU’s, and industrial plants. Implication – focus on point source EGUs’ and industrial facilities.

18. Important Product Produced by VISTAS -- Area of Influence VISTAS developed information based on wind trajectories that indicate the likelihood that a source at a given location will impact each Class I area. A value (RTmax) is determined for each source location that is proportional to each sources probability that it would impact a particular Class I area on days of poor visibility.

19. 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)

20. Explanation of Terms RTmax -- This term is a metric for the frequency that air flows from the source to the Class I area on days of poor visibility. Q – Actual 2002 SO2 emissions in tons per year d – Distance (km), this term is a surrogate for dispersion.

21. Procedure For each unit with SO2 emissions >=250 tpy, identify all EGU’s with an RTmax >=5% and all non-EGU’s with an RTmax>=10% for each Class I area. For each of these units, calculate RTmax*Q/d for each Class I area. For each Class I area, sum RTmax*Q/d over all units and calculate the relative contribution for each unit. Select all units that contribute 0.5% or greater.

22. Proposed Selection (see handouts) 30 Facilities comprising 69 units 17 power plants 4 pulp and paper 9 other (chemical, phosphate,etc.)