WESTAR Fall Technical Conference Regional Haze Rule SIP

WESTAR Fall Technical Conference Regional Haze Rule SIP Template Projection of Improvement Section 51. 309(d)(2) September 17, 2002 Theresa Pella, Arizona DEQ

Projection of Improvement Requirement n Section 309(d)(2): n For each of the 16 mandatory Class I areas…. , the plan must include a projection of improvement in visibility conditions (expressed in deciviews …. . , ) expected through 2018 for the most and least impaired days, based on the implementation of all measures as required in the Commission report and the provisions in this section.

40 CFR 309(d)(2) Projection of Improvement in 16 GCVTC Areas n Template Issues and Status: n What is the requirement for “least impaired” days? n n EPA agreed a showing of “maintenance” is sufficient Tom Moore will provide status of WRAP modeling

40 CFR 309(d)(2) Projection of Improvement in 16 GCVTC Areas n Template Issues and Status: n Should 309 SIPs be “adjusted” if emissions inventories from 308 states used for technical work in 309 SIPs are changed in the 308 state’s SIP? n n Included suggestion in letter to EPA that 309 (d)(10) periodic SIP revisions address Keep in mind 309 requires implementation of GCVTC recommendations, NOT specific levels of emissions reductions

40 CFR 309(d)(2) Projection of Improvement in 16 GCVTC Areas n Template Issues and Status: n Is a 308 state’s emissions inventory data used for a 309 SIP considered an enforceable commitment for the 308 state if not included in the 308 state’s SIP? n Included suggestion in letter to EPA 308 state explain reason for difference in SIP

40 CFR 309 (d)(2) Projection of Improvement in 16 GCVTC Areas n Template Issues and Status: n Does modeling include any non-federal measures/strategies beyond those in GCVTC report? n n WRAP contacted states and locals for measures to be included in 1996 baseline modeling; for 2018, GCVTC and federal measures were added WRAP modeled measures identified in contractors’ reports n n Do states need “centralized list” for SIPs? WRAP provided modeling training for states that may want to update WRAP work for own SIP