1
BART
Comments
Preamble
Questions
Pages
46­
47.
Given
the
uncertainties
identified
in
the
preamble
surrounding
VOC
contributions
to
visibility,
what
is
the
basis
for
EPA's
determination
that
VOC
emissions
need
to
be
controlled
for
the
purpose
of
BART?
Did
EPA
propose
to
include
VOCs?
If
so,
did
EPA
receive
any
comments
on
this
issue?
What
were
the
commenters
concerns?

Page
56.
Are
there
alternative
models
for
>
200
km?

Page
57.
Does
the
model(
s)
yield
estimates
for
multiple
days
or
just
a
single
estimate?
Is
there
any
probabilistic
estimate?

Page
77.
Does
EPA
have
look­
up
tables
ready
to
go?
If
not,
will
it
have
to
re­
propose?

Page
29.
What
is
the
basis
for
EPA's
criterion
that
the
"
20
worst
visibility
days"
are
the
preferred
unit
of
analysis
for
purposes
of
estimating
visibility
improvement?

Pages
39.
Why
should
small
boilers
(
those
less
than
250
MBTU/
hour
in
a
BART
source
category
other
than
electrical
utilities)
be
eligible
for
BART?

Page
59.
How
will
EPA
know
what
visibility
is
under
natural
conditions?

Page
60.
Please
provide
the
memo
describing
alternatives
to
CALPUFF.

Pages
95,
229.
What
evidence
is
there
to
show
that
NOx
control
from
facilities
will
lead
to
visibility
improvement?
For
SO2
control,
EPA
presents
modeling
results,
but
no
such
modeling
results
are
provided
for
NOx.

Page
98.
What
are
the
"
EPA
approved
methods"
for
evaluating
visibility
at
less
than
50
km,
aside
from
CALPUFF?

Page
112
Why
wouldn't
this
rule
be
considered
an
unfunded
mandate?
It
imposes
costs
greater
than
$
100
million
annually
on
the
private
sector.

Page
113.
Why
aren't
there
Federalism
implications?
States
have
to
do
much
work
under
this
rule.

Page
114.
Why
aren't
there
tribal
implications?

Page
121
Why
aren't
there
energy
impacts?

RIA
Questions
2
Page
4­
66.
The
last
two
sentences
in
footnote
17
are
not
necessary
and
can
be
removed.

Page
4­
66.
The
statement
that
use
values
associated
with
visibility
include
improved
road
and
air
safety
should
be
supported
by
relevant
citations
or
other
evidence.
The
statement
that
improved
visibility
enhances
recreational
activities
like
hunting
and
birdwatching
should
also
be
supported
by
evidence.

Pages
4­
66
and
4­
67.
The
paragraph
describing
McClelland
et
al.
(
1993)
and
Chestnut
and
Rowe
(
1990)
should
be
revised
as
follows:

Only
one
existing
study
provides
monetary
estimates
of
the
value
of
visibility
changes.
It
is
a
1988
survey
on
recreational
visibility
value
(
Chestnut
and
Rowe
1990a,
1990b).
While
there
are
a
number
of
other
studies
in
the
literature,
they
were
conducted
in
the
early
1980s
and/
or
did
not
use
methods
that
are
considered
defensible
by
current
standards.
The
chestnut
and
Rowe
study
utilizes
the
contingent
valuation
method.
There
has
been
a
great
deal
of
controversy
and
significant
development
of
both
theoretical
and
empirical
knowledge
about
how
to
conduct
CV
surveys
in
the
past
decade.
In
EPA's
judgment,
the
Chestnut
and
Rowe
study
contains
some
of
the
key
elements
of
a
valid
CV
study.
Despite
its
shortcomings,
it
remains
the
best
study
available,
and
therefore
we
used
it
in
this
analysis.
This
study
serves
as
an
essential
input
to
our
estimates
of
the
benefits
of
recreational
visibility
improvements
in
the
primary
benefits
estimates.
Another
study
(
McClelland
et
al.
1993)
attempted
to
value
residential
visibility.
Consistent
with
SAB
advise,
EPA
has
designated
the
McClelland
et
al.
study
as
significantly
less
reliable
for
regulatory
cost­
benefit
analysis,
although
it
does
provide
estimates
of
residential
visibility
benefits
(
EPA­
SAB­
COUNCIL­
ADV­
00­
002,
1999).

Page
4­
68.
EPA
states
that
the
benefit
estimates
incorporate
Chestnut's
estimate
that
a
1%
increase
in
income
is
associated
with
a
0.9%
increase
in
WTP
for
a
given
change
in
visibility.
Does
Chestnut
and
Rowe
lend
itself
to
this
type
of
calibration?

Page
4­
68.
Somewhere
in
this
section,
EPA
should
include
a
list
of
the
underlying
uncertainties
with
Chestnut
and
Rowe,
including
how
dated
it
is.

More
comments
on
the
RIA
will
be
forthcoming.

SBA
Advocacy
Comments
Our
discussions
with
small
business
representatives
concerning
the
potential
impact
of
regional
haze
provisions
suggest
that
EPA
needs
to
look
harder
at
the
economic
impacts
on
non­
utility
facilities
(
e.
g.,
lime
manufacturing
plants).
Several
small
lime
manufacturers
are
likely
to
be
affected
by
the
rule.
The
current
focus
of
the
Preamble/
RIA
is
on
utility
impacts.
Also
EPA
needs
to
develop
a
more
detailed
idea
of
specific
small
community(
especially
municipal
utility)
impacts.
EPA
needs
therefore
needs
to
give
better
consideration
in
the
Preamble/
RIA
to:

­
economic
impacts
on
the
non­
utility
BART­
eligible
industrial
categories;
3
­
impacts
on
small
communities,
particularly
municipal
utilities.

DoD
Comments
The
Clean
Air
Act
Services
Steering
Committee,
which
represents
the
Departments
of
the
Army,
Navy,
Air
Force,
and
other
Department
of
Defense
(
DoD)
components
and
agencies,
reviewed
the
draft
proposed
rule
on
Regional
Haze
Regulations
and
Guidelines
for
Best
Available
Retrofit
Technology
(
BART)
Determinations.
We
support
the
proposed
changes
to
the
Regional
Haze
rule
and
BART
guidelines.
We
suggest,
however,
clarification
of
one
item
in
the
proposal.

Although
we
support
the
clarifications
made
to
the
source
category
titles,
we
are
unclear
as
to
whether
the
source
category
called
"
steam
electric
plants
of
more
than
250
million
BTU/
hr
heat
input"
is
referring
to
steam
electric
plants
in
the
same
way
as
EPA
refers
to
electric
utility
steam
generating
units
(
EUSGU)
in
other
CAA
rules.
Is
this
source
category
referring
to
utility
plants
that
generate
electricity
for
sale
or
is
it
referring
to
any
steam
plant
located
at
a
facility
that
uses
all
or
some
portion
of
the
generated
steam
to
generate
electricity,
even
if
all
the
electricity
is
used
internally
by
the
facility?
The
discussion
in
the
preamble
to
this
draft
rule
does
not
address
this
question.
The
Prevention
of
Significant
Deterioration
rules
(
40
CFR
52.21),
referenced
in
this
Regional
Haze
proposal,
does
not
specify
whether
the
source
category
covers
all
steam
electric
plants
or
only
those
that
generate
electricity
for
sale.

We
support
the
options
given
to
States
in
the
BART
guidelines
for
determining
which
BART­
eligible
sources
"
may
reasonably
be
anticipated
to
cause
or
contribute
to
any
impairment
of
visibility
in
any
mandatory
Class
I
Federal
area."
The
discretion
given
to
the
States
to
use
a
case­
by­
case
or
a
cumulative
analysis
of
BART
applicability
affords
States
the
opportunity
to
implement
the
Regional
Haze
program
in
the
way
best
suited
to
their
situation.
We
will
work
closely
with
each
State
where
we
have
BART­
eligible
sources.

In
our
November
26,
1997
comments
to
EPA
on
the
proposed
Regional
Haze
rule,
we
requested
that
the
timelines
for
implementation
of
the
Regional
Haze
rule
and
PM2.5
National
Ambient
Air
Quality
Standard
be
aligned.
The
Omnibus
Appropriations
Act
of
2004
set
forth
a
common
schedule
for
States
to
submit
State
Implementation
Plans
for
the
two
rules.
We
believe
this
is
a
logical
way
to
streamline
the
process
for
these
two
interrelated
rules.

We
look
forward
to
seeing
the
draft
rule.
Thank
you
for
providing
us
with
an
opportunity
to
review
the
proposal
before
the
draft
is
published.
