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VISTAS Reasonable Progress Discussion November 15, 2005

VISTAS Reasonable Progress Discussion November 15, 2005. Demonstrating Reasonable Progress. Rule suggests following steps 1. Compare baseline visibility conditions to natural background conditions 2. Identify uniform rate of progress (URP)

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VISTAS Reasonable Progress Discussion November 15, 2005

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  1. VISTAS Reasonable Progress Discussion November 15, 2005

  2. Demonstrating Reasonable Progress • Rule suggests following steps • 1. Compare baseline visibility conditions to natural background conditions • 2. Identify uniform rate of progress (URP) • 3. Identify where the Class I area would be if the URP is achieved by 2018 • 4. Identify measures needed to achieve URP • Are measures reasonable based on statutory factors?

  3. Demonstrating Reasonable Progress • 5. Consultation with other States to establish reasonable progress goals • 6. States can determine one of three things: • URP is reasonable • Doing more than URP is reasonable • Doing less than URP is reasonable • All determinations must be measured against the statutory factors

  4. Demonstrating Reasonable Progress • Statutory factors: • Cost of compliance • Time necessary for compliance • Energy and non-air quality environmental impacts of compliance • Remaining useful life of any existing source subject to such requirements

  5. VISTAS Status on Reasonable Progress • Progress to Date • Remaining Work

  6. Demonstrating Reasonable Progress For each VISTAS Class I area: • Identified pollutants contributing to PM2.5 and visibility • Identified probable source areas using back trajectories and residence time • Developed emissions inventories for 2002, 2009, 2018 • Applied CMAQ air quality model to evaluate planned controls and compare to uniform rate of progress • On the Way (OTW) controls including CAIR + CAMR • EGU emissions from IPM assuming least-cost trading • Evaluate alternative EGU emissions assuming CAIR trading only within a state (not yet complete)

  7. VISTAS Progress to Date – Base D

  8. Demonstrating Reasonable Progress • Evaluated sources within 200 km of Class I area and within highest probability source areas • Defined major source categories, individual sources, expected OTW controls, and potential future control options

  9. Limited Geography AnalysisCounties within 200km of ROMA

  10. Source Type 2018 BaseFAnnual Emissions (Tons) - ROMA

  11. Source Type 2018 BaseFAnnual Emissions (Percent) - ROMA

  12. Source Type 2018 BaseFAnnual Emissions (Percent) - ROMA

  13. Source Type 2002 to 2018 BaseFAnnual Emissions Change - ROMA

  14. Demonstrating Reasonable Progress- Work to Do 6. Run CMAQ to estimate benefits from BART + OTW (CAIR) controls and compare to uniform progress • Sources subject to BART defined by States in spring 2006. • CMAQ sensitivity run in winter 2006 will define potential benefits of estimated BART controls; run is not a regulatory demonstration. • For all Class I areas, evaluate candidate control measures beyond CAIR and BART • Work is underway with AIRControlNet to get cost estimates on control technologies for point sources – Special thanks to Dan Cohan of Georgia for leading this effort. 9. Define control strategies to run in CMAQ 10. Finalize the reasonable progress definition for each area as part of the SIP

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