Comments
on
Regional
Haze
Regulations
and
Guidelines
for
BART
General
comments:

1.
EPA
should
consider
adding
language
to
the
preamble
to
indicate
what
has
been
done
to
help
ensure
consistency
between
this
rulemaking
and
other
rulemakings
that
involve
some
of
the
same
pollutant(
s).
A
given
source
might,
for
example,
be
planning
to
buy
SO2
allowances
to
comply
with
one
regulation
only
to
find
that
the
instant
rulemaking
would
require
the
installation
of
control
technology
to
address
the
same
emissions.

2.
The
comment
period
should
be
lengthened
to
at
least
60
days.

3.
A
table
of
contents
should
be
added
to
assist
the
potential
commenters
in
making
reference
to
sections
of
the
proposed
rulemaking.
The
notation
for
headings
and
subheadings
should
be
revised
to
allow
easier
identification
of
sections.

Specific
comments:

p.
39
Agree
with
EPA's
interpretation
of
"
fossil­
fuel
boilers
of
more
than
250
million
BTU/
hr
heat
input."

p.
40
Agree
with
EPA's
interpretation
of
"
fossil
fuel."

p.
44
Agree
with
EPA's
proposal
not
to
include
ammonia
among
pollutants
to
be
addressed.

p.
47
Agree
with
EPA's
request
for
comment
on
VOC
control.

p.
50
Agree
with
EPA's
proposal
to
give
States
the
flexibility
to
identify
de
minimis
levels
of
pollutants
at
BART­
eligible
facilities.

p.
54
Would
EPA
provide
or
develop
a
standard
modeling
protocol
for
use
of
CALPUFF
for
distance
greater
than
250
km?

p.
57
The
threshold
level
for
a
"
just
noticeable
change"
is
proposed
to
be
5%.
As
stated
on
page
58,
"
this
level
would
be
calculated
by
measuring
the
air
quality
screening
modeling
results
for
an
individual
source
against
natural
visibility
conditions".
First,
what
guidance
is
provided
for
the
determination
of
"
natural
visibility
conditions"
are
for
a
particular
area?
Second,
why
use
this
baseline
to
determine
the
degree
of
impairment?
Third,
how
will
transported
pollution
that
could
impact
visibility
conditions,
especially
in
establishing
the
baseline
"
natural
visibility
conditions"
be
addressed?
(
This
should
be
addressed
in
"
Section
4,
Step
4:
For
a
BART
engineering
analysis,
what
impacts
must
I
calculate
and
report?
What
methods
does
EPA
recommend
for
the
impacts
analysis",
page
194.)
p.
69
EPA
doesn't
really
say
what
the
cutoff
might
be
between
technologies
that
are
to
be
considered
"
cost­
effective"
and
those
considered
otherwise.
Is
this
to
be
left
up
to
the
States?

p.
72
This
statement
is
unclear:
"
Also,
a
few
sources
may
emit
higher
than
acceptable
levels
of
Nox
[
sic]
even
after
consideration
of
screening
levels."

p.
73
In
the
preamble,
EPA
discusses
the
"
nonair
quality"
impacts
but
doesn't
discuss
the
"
energy"
impacts
as
included
in
Section
169A(
g)(
7)(
2).
Why
not
include
in
the
preamble
some
of
the
discussion
contained
in
the
draft
Guidelines
at
211
et
seq.?

p.
75
There
is
a
discussion
of
the
potential
for
BART
control
of
a
visibility­
related
pollutant
to
interfere
with
the
control
of
mercury.
The
"
air
quality
and
nonair
quality
related
environmental
concerns"
mentioned
here
would
seem
to
come
into
play
when
a
BART­
eligible
source
emits
more
than
two
visibility­
related
pollutants
in
greater
than
de
minimis
amounts.
Would
there
be
any
opportunity
for
States
to
consider
the
costs
and
benefits
of
co­
control
with
various
technologies
or
combinations
of
technologies?
For
example,
once
a
sourcespecific
BART
determination
is
made
for
two
regulated
pollutants,
and
if
the
result
is
two
different
BART
technologies
that
don't
work
well
together,
could
a
State
then
substitute
one
technology
or
combination
of
technologies
that
achieved
at
least
the
same
emissions
reductions
for
each
pollutant
at
a
lower
cost?

p.
76
The
text
blurs
the
difference
between
the
"
cost
of
control"
and
the
"
cost
of
compliance."
Shouldn't
the
costs
of
compliance
be
those
costs
associated
with
achieving
the
required
level
of
visibility
impairment
reduction,
i.
e.,
compliance?

p.
77
SO2
controls
for
utility
boilers.

Why
does
EPA
believe
there
is
a
need
to
establish
a
"
default"
percentage
control
level
for
750
MW
and
greater
plants?
There
is
apparently
nothing
like
this
for
any
other
source
category,
and
the
statutory
requirement
that
the
applicable
emission
limitations
"
be
determined
pursuant
to
[
EPA]
guidelines"
could
be
satisfied
without
the
default
level,
regardless
of
what
"
Congress
understood
25
years
ago."
EPA
even
mentions
(
p.
84)
that
many
utility
industry
comments
were
critical
of
the
similar
provision
in
the
2001
regulation
as
a
Federal
mandate
that
would
reduce
State
flexibility.
This
concern
regarding
flexibility
does
not
seem
to
have
been
addressed
in
the
instant
rulemaking.
If
the
case
for
95
percent
reduction
using
FGD
is
really
so
airtight,
why
wouldn't
States
end
up
selecting
this
as
BART
anyway
without
the
default
provision?

Also,
EPA
uses
the
terms
"
default
level"
and
"
presumptive
level,"
but
does
say,
as
it
does
for
250­
750
MW
plants
whether
these
levels
would
be
"
rebuttable."
Would
they
be?
If
not,
why
not?
Why
should
there
be
the
restriction
stated
in
footnote
29?
Why
not
follow
the
procedures
that
would
be
used
for
other
categories
of
sources
and
let
States
evaluate
various
configurations
of
scrubbers?

It
is
also
mentioned
(
p.
79)
that
some
comments
"
recommended
that
the
presumptive
level
be
expressed
as
a
performance
level."
It
is
doubtful
that
they
meant
for
the
performance
level
to
be
added
to
a
requirement
for
95
percent
control.
Why
does
EPA
believe
(
p.
85)
there
a
need
for
both?
What
does
accounting
"
for
the
difference
between
coal
with
higher,
as
opposed
to
lower,
sulfur
content"
have
to
do
with
EPA's
rationale?
If
there
is
to
be
a
default
percentage
reduction
requirement,
why
wouldn't
this
be
less
than
95
percent
where
BART­
eligible
sources
have
already
limited
their
sulfur
dioxide
emissions
by
using
lower­
sulfur
coal?

Why
is
there
a
need
for
the
rebuttable
presumption
for
250­
750
MW
plants
(
p.
80)?

Why
is
there
a
need
to
propose
the
same
control
level
for
250
MW
boilers
at
750
MW
and
above
plants
as
for
250
MW
boilers
at
smaller
plants
(
p.
88)?
Can't
States
make
a
determination
on
this
issue
themselves?

p.
89
NOx
control
for
utility
boilers.

Why
does
EPA
believe
there
is
a
need
to
require
that
sources
using
SCR
on
a
seasonal
basis
operate
SCR
year­
round?
EPA
provides
no
rationale
for
this
based
on
expected
environmental
impacts.
Why
not
determine
BART
for
NOx
control
in
the
usual
way?

Similarly,
why
does
EPA
propose
(
p.
94)
that
States
for
"
all
other
power
plants
subject
to
BART
 
,
as
a
general
matter,
"
require
these
sources
to
achieve
a
control
level
of
0.2
lbs/
MMBtu?"
Does
this
statement
refer
only
to
plants
subject
to
BART
for
NOx
or
for
any
of
the
pollutants
proposed
to
be
regulated
under
the
instant
rule?"
Is
it
correct
that
EPA
intends
this
"
general
matter"
requirement
to
apply
to
"
plants,"
as
stated,
or
to
individual
boilers?

p.
96
Consideration
of
visibility
impacts.

There
is
no
rationale
given
for
choosing
the
running
of
CALPUFF
and
tabulating
the
results
"
for
the
average
of
the
20%
worst
modeled
days
at
each
receptor"
as
the
sole
proposed
option.
Why
not
propose
two
options
and
ask
for
comment:
(
1)
running
CALPUFF,
or
(
2)
the
alternative
option
"
of
using
the
hourly
modeled
impacts
from
CALPUFF
and
assessing
the
improvement
in
visibility
based
on
the
number
of
hours
above
a
visibility
threshold
for
the
pre­
and
post­
control
emission
rates."
What
is
meant
by
"
each
receptor?"
It
makes
sense
to
assess
impacts
for
the
entirety
of
a
given
Class
I
area,
but
are
there
already
pre­
defined
receptor
coordinates
that
together
cover
the
entire
area?

If
the
alternative
method
is
used,
how
should
States
assess
a
given
number
of
hours
above
a
visibility
threshold?

p.
99
Trading
program
Agree
with
providing
the
option
of
trading
programs
including
non­
BART
sources.

As
mentioned
on
p.
100,
the
WRAP
emissions
trading
program
is
a
"
backstop"
program.
Under
the
re­
proposal,
would
any
emissions
trading
programs
necessarily
be
backstop
programs?

Would
the
requirement
that
a
trading
program
"
achieve
greater
reasonable
progress"
essentially
require
a
State
wanting
to
participate
in
a
trading
program
to
first
complete
BART
determinations
for
all
BART­
eligible
sources
individually
or
collectively?
