Purpose:  

  SEQ CHAPTER \h \r 1 This checklist has been prepared by EPA staff to
use in reviewing regional haze SIPs to ensure that the SIPs have the
necessary components.  The checklist represents our best efforts to
summarize the requirements of the regional haze rule but it is not a
regulation and does not change or substitute for any legal requirements
in the Clean Air Act (CAA) or the regional haze rule.  Any decisions
regarding the completeness of a particular SIP will be made based on the
CAA and the relevant regulations.  Therefore, interested parties are
free to raise questions and objections to the checklist and its use in a
particular situation.

Acronyms and Terms:

BART is Best Available Retrofit Technology

CAA is the Clean Air Act

CAIR is Clean Air Interstate Rule

EI is Emissions Inventory

FLM is Federal Land Manager

Glidepath is the linear rate of improvement sufficient to attain natural
conditions by 2064

LTS is Long Term Strategy

RAVI is Reasonably Attributable Visibility Impairment

RHR is the Regional Haze Rule

RPO is Regional Planning Organization 

RPG is Reasonable Progress Goal

Notes:

1.	This checklist is based on Appendix V to 40 CFR Part 51, and 40 CFR
51.308, as updated by the BART Rule (70 FR 39104, July 6, 2005), and the
trading rule, as proposed in 70 FR 44154, August 1, 2005.  This
checklist will be revised if necessary, should that be necessitated by
the final version of the trading rule.   

2.	All boxes should either be “Y” or “N/A” or the SIP may be
deficient.

3.	This checklist assumes the State will not be participating in a
trading program, or other alternative measure to BART.  If this is not
the case, then additional/alternative regulations that appear in
51.308(e)(2) and (3) apply.

4.	Only the requirements from 51.308 pertaining to the current RH SIP
submission, and not those pertaining to future revisions and/or reports
required under 51.308(f), (g), and (h) (except for a SIP commitment to
do them), were included.

5.	The “1999 RHR” is 64 FR 35714, July 1, 1999.

The “2005 BART Rule” is 70 FR 39104, July 6, 2005.

The “BART Guidelines” is Appendix Y to Part 51—Guidelines for BART
Determinations Under the Regional Haze Rule, 70 FR 39104, July 6, 2005.

The “Tracking Guidance” is the Guidance for Tracking Progress Under
the Regional Haze Rule, EPA-454/B-03-004, September, 2003.

The “Attainment Guidance” is the Draft Guidance for Demonstrating
Attainment of Air Quality Goals for PM2.5 and Regional Haze, January 2,
2001.

The “Natural Visibility Guidance” is the Guidance for Estimating
Natural Visibility Conditions Under the Regional Haze Rule,
EPA-454/B-03-005, September 2003.

The “Baseline Memo” is a memo, 2002 Base Year Emission Inventory SIP
Planning: 8-Hour Ozone, PM2.5 and Regional Haze Programs, dated
11/18/2002, from Lydia Wegman to the Regional Air Directors.

The “draft RPG Guidance” is the Draft Guidance for Setting
Reasonable Progress Goals Under the Regional Haze Program, dated
November 28, 2005.

The “Visibility Monitoring Guidance” is Visibility Monitoring
Guidance, EPA-454/R-99-003, June 1999.

The “EI Guidance” is the Emissions Inventory Guidance for
Implementation of Ozone and Particulate Matter National Ambient Air
Quality Standards (NAAQS) and Regional Haze Regulations,
EPA-454/R-05-001, dated August, 2005.

The “Interim Fire Policy” is the Interim Air Quality Policy on
Wildland and Prescribed Fires, April 23, 1998.

*	Requirements that do not apply to States without Class I areas are
denoted by an asterisk.



Y / N or N/A

SIP Submittal Checklist for Regional Haze SIPs Submitted under 40 CFR
51.308



Regulation Citation	Regulation Summary (not verbatim)	Location

in SIP	References



Administrative Requirements from Appendix V to Part 51

Y

2.1(a)	Has a letter of submittal from the governor / designee,
requesting EPA approval of the SIP been received?	Cover letter w/
attachment

	Y

2.1(b)	Has the State provided evidence it has adopted the legally
enforceable portions of the plan in the State code or body of
regulations; or issued the necessary permits, orders, consent agreements
in final form?	Subsection 11.10

	Y

2.1(c)	Has the State provided evidence it has the necessary legal
authority under State law to adopt and implement the plan?	Subsection
11.10

	Y

2.1(d)	Has the official State regulation /document been
signed/stamped/dated by the appropriate State official indicating that
it is fully enforceable by the State?	Cover letter w/ attachment

	Y

2.1(e)	Has the State provided evidence it followed all of the procedural
requirements of the State’s laws and constitution in the
adoption/issuance of the plan?	Cover letter w/ attachment



	2.1(f)	Has the State provided evidence that public notice was given of
the proposed change consistent with procedures approved by EPA,
including the date of publication of such notice?	(near future)



	2.1(g)	Has the State provided a certification that public hearings(s)
were held in accordance with the information provided in the public
notice and the State’s laws and constitution, if applicable?	(near
future)



	2.1(h)	Has the State provided a compilation of public comments and the
State’s response thereto?	(Compilation will follow.)



	Technical  Requirements from 40 CFR 51.308

N

(b)	Was the SIP submitted no later than December 17, 2007?	SIP was
submitted on January 30, 2009

	Y

(d)	Did the State provide a table identifying each mandatory Class I
Federal area located within the State and in each mandatory Class I
Federal area located outside the State affected by emissions from within
the State?	Subsection 2.1,   Table 2.1	 Visibility Monitoring Guidance



NA	*	(d)(1)	Did the State establish RPGs for each Class I area that
provide for an improvement in visibility for the most impaired days over
the period of the SIP, and ensure no degradation in visibility for the
least impaired days over the same period?

 p. 35730 of the 1999 RHR

 p. 1-6 of the Tracking Guidance

 Attainment Guidance

 draft RPG Guidance



NA	*	(d)(1)(i)(A)	In establishing RPGs for each Class I area, did the
State consider the costs of compliance, the time necessary for
compliance, the energy and non-air quality environmental impacts of
compliance, and the remaining useful life of any potentially affected
sources, and include a demonstration showing how these factors were
taken into consideration in selecting the goal?

 p. 35731-33 of the 1999 RHR

 draft RPG Guidance



NA	*	(d)(1)(i)(B)	Did the State submit the glidepath (i.e., rate of
progress needed to attain natural visibility conditions by 2064) for
each Class I area?

 p. 35727-33, 35 of the 1999 RHR

 Natural Visibility Guidance

 p. 39124, 39143 of the 2005 BART rule

The Baseline Memo

NA	*	(d)(1)(i)(B)	In establishing the RPG for each Class I area, did the
State calculate the uniform rate of improvement in visibility and the
emission reduction measures needed to achieve it for the period covered
by the SIP?

 p. 35732 of the 1999 RHR

 draft RPG Guidance



NA	*	(d)(1)(ii)	If the State establishes a RPG < the glidepath, has it
demonstrated, based on the factors in (d)(1)(i)(A), the rate of progress
for the SIP to attain natural conditions by 2064 is not reasonable, and
its RPG is reasonable?

 p. 35732 of the 1999 RHR



NA	*	(d)(1)(ii)	If the State establishes a RPG < the glidepath, did it
provide to the public for review as part of its SIP, an assessment of
the number of years it would take to attain natural conditions using its
RPG?

 p. 35732 of the 1999 RHR



NA

(d)(1)(iv)	In developing its RPG, has the State consulted with those
States that may reasonably be anticipated to cause or contribute to
visibility impairment in the Class I areas?

 p. 35735 of the 1999 RHR



NA

(d)(1)(iv)	If the State cannot agree with another State(s) that a goal
provides for reasonable progress, has the State described in its
submittal the actions taken to resolve the disagreement?	Section 3	 p.
35732 of the 1999 RHR



NA	*	(d)(1)(vi)	Has the State adopted RPGs that represents at least the
visibility improvement expected from implementation of other CAA
programs during the applicable planning period?

 p. 35733 of the 1999 RHR



NA	*	(d)(2)(i)	Has the State calculated baseline visibility conditions
for each Class I area for the most impaired and least impaired days
using 2000 to 2004 monitoring data?

 p. 35728-30 of the 1999 RHR

 Natural Visibility Guidance

 Attainment Guidance

Tracking Guidance

NA	*	(d)(2)(i)	In calculating the baseline visibility conditions, did
the State estimate the average degree of visibility impairment for the
most and least impaired days for each calendar year from 2000 to 2004,
and then determine the average of these annual values?



NA	*	(d)(2)(i)	If the State has Class I areas without onsite monitoring
data for 2000 - 2004, did the State use the most representative
available monitoring data for 2000 - 2004 to establish baseline values,
in consultation with the EPA Regional Office?

 p. 35728-29 of the 1999 RHR

 Visibility Monitoring Guidance



NA	*	(d)(2)(iii)	Did the State calculate natural visibility conditions
for the most impaired and least impaired days by estimating the degree
of impairment based on available monitoring information and appropriate
data analysis techniques?

 p. 35764, 35729-30 of the 1999 RHR

 Natural Visibility Guidance



NA	*	(d)(2)(iv)A	Did the State calculate the number of deciviews by
which baseline conditions exceed natural visibility conditions for the
most impaired and least impaired days for the first planning period?

 p. 35732 of the 1999 RHR



Y

(d)(3)	Did the State submit a LTS that addresses visibility impairment
for each Class I area, inside and outside the State, which may be
affected by the State’s emissions?	Section 11.0	 p. 35734-35 of the
1999 RHR



Y

(d)(3)	Does the LTS include enforceable emissions limitations,
compliance schedules, and other measures as necessary to achieve the
RPGs established by States having Class I areas?	Subsection 11.10 	 p.
35734-35 of the 1999 RHR



Y

(d)(3)(i)	In establishing its LTS, did the State consult with other
State(s) to develop coordinated emission management strategies for cases
in which it has emissions that are reasonably anticipated to contribute
to visibility impairment in any Class I area located in those State(s)?
Section 3.0	 p. 35735 of the 1999 RHR



Y

(d)(3)(i)	In establishing its LTS, did the State consult with other
State(s) to develop coordinated emission management strategies for cases
in which those State(s) have emissions that are reasonably anticipated
to contribute to visibility impairment in any Class I area located
within the State?	Section 3.0

	Y

(d)(3)(ii)	In establishing its LTS, where multiple State(s) cause or
contribute to impairment of the same Class I area, did the State include
all measures necessary to obtain its share of the emission reductions
needed to meet the RPG for the area?	Subsection 11.9	 p. 35735 of the
1999 RHR



Y

(d)(3)(ii)	In addressing (d)(3)(ii), above, if the State participated in
a RPO, did it ensure it included all measures needed to achieve its
apportionment of emission reduction obligations agreed upon through that
process?	Subsection 11.9	 p. 35735 of the 1999 RHR



Y

(d)(3)(iii)	In establishing its LTS, did the State document the
technical basis, including modeling, monitoring and emissions
information, on which it is relying to determine its apportionment of
emission reduction obligations necessary for achieving reasonable
progress in each Class I area it affects?	Subsections 11.1 and 11.2	 p.
35735 of the 1999 RHR

 EI Guidance



Y

(d)(3)(iii)	In addressing (d)(3)(iii), above, did the State identify the
baseline emissions inventory on which its strategies are based?
Subsection 6.1,  Part 6.1.1 and Subsections 11.1 and 11.2	 p. 35728 of
the 1999 RHR

 Baseline Memo

EI Guidance

Y

(d)(3)(iv)	Did the State identify all anthropogenic sources of
visibility impairment considered by it in developing its LTS, including
consideration of major and minor stationary sources, mobile sources, and
area sources?	Section 8.0	 p. 35735 of the 1999 RHR

 EI Guidance



Y

(d)(3)(v)(A)	In developing its LTS, did the State consider the emission
reductions due to ongoing air pollution control programs, including
measures to address RAVI?	Subsection 11.3	 p. 35737 of the 1999 RHR



Y

(d)(3)(v)(B)	In developing its LTS, did the State consider measures to
mitigate the impacts of construction activities?	Subsection 11.6	 p.
35737 of the 1999 RHR



Y

(d)(3)(v)(C)	In developing its LTS, did the State consider emissions
limitations and schedules for compliance to achieve the reasonable
progress goal?	Subsection 11.10	 p. 35737 of the 1999 RHR



Y

(d)(3)(v)(D)	In developing its LTS, did the State consider source
retirement and replacement schedules?	Subsection 11.5	 p. 35737 of the
1999 RHR



Y

(d)(3)(v)(E)	In developing its LTS, did the State consider smoke
management techniques for agricultural and forestry management purposes,
including plans as currently exist within the State for these purposes?
Subsection 11.7	 p. 35736 of the 1999 RHR

 Interim Fire Policy



Y

(d)(3)(v)(F)	In developing its LTS, did the State consider
enforceability of emissions limitations and control measures?	Subsection
11.8	 p. 35737 of the 1999 RHR



Y

(d)(3)(v)(G)	In developing its LTS, did the State consider the
anticipated net effect on visibility due to projected changes in point,
area, and mobile source emissions over the period addressed by the LTS?
Section 11.8	 p. 35737 of the 1999 RHR



NA	*	(d)(4)	Did the State submit with the SIP a monitoring strategy for
measuring, characterizing, and reporting of regional haze visibility
impairment representative of all Class I areas within the State?

 p. 35744 of the 1999 RHR

 Attainment Guidance

 Tracking Guidance

Visibility Monitoring Guidance

NA	*	(d)(4)	Did the State coordinate the above monitoring strategy with
the RAVI monitoring strategy in § 51.305?

 p. 35717, 37,  of the 1999 RHR



NA	*	(d)(4)(i)	Did the SIP provide for the establishment of any
additional monitoring sites or equipment needed to assess whether RPGs
to address regional haze for all Class I areas within the State are
being achieved?

 p. 35744 of the 1999 RHR

  Attainment Guidance

 Tracking Guidance

Visibility Monitoring Guidance

NA	*	(d)(4)(ii)	Did the SIP establish procedures by which monitoring
data and other information are used in determining the contribution of
emissions from within the State to regional haze visibility impairment
at Class I areas both within and outside the State?

 p. 35744 of the 1999 RHR

 Attainment Guidance

 Tracking Guidance

 Visibility Monitoring Guidance



Y

(d)(4)(iii)	For a State with no Class I areas, did the SIP establish
procedures by which monitoring data and other information are used in
determining the contribution of emissions from within the State to
regional haze visibility impairment at Class I areas in other States?
Section 5	 p. 35744 of the 1999 RHR

 Attainment Guidance

 Tracking Guidance

 Visibility Monitoring Guidance



NA	*	(d)(4)(iv)	Did the SIP provide for the reporting of all visibility
monitoring data to EPA at least annually for each Class I area in the
State?

 p. 35744-45 of the 1999 RHR

 Visibility Monitoring Guidance



Y

(d)(4)(v)	Did the SIP include a statewide EI of pollutants that are
reasonably anticipated to cause or contribute to visibility impairment
in any Class I area?	Section 6.0 and Subsection 8.2	 Attainment Guidance



Y

(d)(4)(v)	Did the EI include emissions for a baseline year, emissions
for the most recent year for which data are available, and estimates of
future projected emissions?	Section 6.0 (The 2002 EI data represent both
the baseline year and the most recent year for which reliable data a	 p.
35728-29 of the 1999 RHR

 Visibility Monitoring Guidance

Attainment Guidance



(d)(4)(v)	Did the SIP include a commitment to update the EI
periodically?	Subsection 1.3,   Part 1.3.2	 EI Guidance





(d)(4)(vi)	Did the SIP include other elements necessary to assess and
report on visibility (e.g., reporting, recordkeeping, etc.)?	Subsection
5.2

	NA

(e)	Did the State submit a SIP containing emission limitations
representing BART, and schedules for compliance with BART, for each BART
eligible source that may reasonably be anticipated to cause or
contribute to any impairment of visibility in any Class I area?

 BART Guidelines



NA

(e)(1)(i)	Did the SIP include a list of all BART-eligible sources within
the State with supporting documentation?

 BART Guidelines



NA

(e)(1)(ii)	Did the SIP include a determination of BART for each
BART-eligible source in the State that emits any air pollutant which may
reasonably be anticipated to cause or contribute to any impairment of
visibility in any Class I area?

 BART Guidelines



NA

(e)(1)(ii)(A)	Did the SIP include a determination of BART based on an
analysis of the best system of continuous emission control technology
available, and associated emission reductions achievable for each source
subject to BART within the State?

 BART Guidelines



NA

(e)(1)(ii)(A)	In the BART analysis, did the State take into
consideration the technology available, the costs of compliance, the
energy and nonair quality environmental impacts of compliance, any
pollution control equipment in use at the source, the remaining useful
life of the source, and the degree of improvement in visibility which
may reasonably be anticipated to result from the use of such technology?

 BART Guidelines 

 p 39107, 127 of the 2005 BART Rule



NA

(e)(1)(ii)(B)	Did the State determine BART for fossil-fuel fired power
plants > 750 megawatts pursuant to the BART guidelines?

 BART Guidelines

 p 39108 of the 2005 BART Rule

NA

(e)(1)(iii)	If the State has determined that technological or economic
limitations on the applicability of measurement methodology to a
particular source would make the imposition of an emission standard
infeasible, has the State prescribed a design, equipment, work practice,
or other operational standard, to require the application of BART, as an
alternative to a BART emission standard?

 BART Guidelines



NA

(e)(1)(iii)	If the State adopted a design, equipment, work practice, or
other operational standard alternative to BART, did the State, to the
degree possible, set forth the emission reduction to be achieved, and
provide for compliance by means which achieve equivalent results?

 BART Guidelines

 p 39172 of the 2005 BART Rule



NA

(e)(1)(iv)	Has the State required each source subject to BART to install
and operate BART as expeditiously as practicable, but no later than 5
years after approval of the SIP?

 p 39158, 70, 72 of the 2005 BART Rule



NA

(e)(1)(v)	Has the State required each BART source to maintain the
required control equipment and establish procedures to ensure such
equipment is properly operated and maintained?

 p 39172 of the 2005 BART Rule



NA

(e)(4)	If the State is using its participation in CAIR to exempt
BART-eligible EGU’s from BART, has it included supporting
documentation?

 p 39136-42 of the 2005 BART Rule



NA

(e)(4)	If the State is using its participation in CAIR to exempt
BART-eligible EGU’s from BART, did it include provisions for a
geographic enhancement to the program to address RAVI BART under §
51.302(c)?

 p 39143, 57 of the 2005 BART Rule



NA

(e)(6)	If a facility is seeking an exemption under §51.303(a)(2)–(h)
for any of its BART-eligible emission units, has the appropriate
documentation been included in the SIP?

 §51.303(a)(2)–(h)



Y

(f)	Has the State included a commitment it will submit its SIP revision,
as specified in 51.308(f), by July 31, 2018, and every ten years
thereafter?	Subsection 1.3,    Part 1.3.2	p 35745 of the 1999 RHR

 Section 110(a)(2)(H) of the CAA

Y

(g)	Has the State included a commitment it will submit its SIP report,
as specified in 51.308(g), by an exact date named, that is within 5
years from submittal of the initial SIP?	Subsection 1.3,    Part 1.3.2	p
35745 of the 1999 RHR

 Section 110(a)(2)(F) of the CAA

Y

(h)	Has the State included a commitment it will, at the time of the
submission of the SIP report, also submit a determination of the
adequacy of its existing Regional Haze SIP revision, as specified in
51.308(h)?	Subsection 1.3,    Part 1.3.2	p 35745 of the 1999 RHR

 Section 110(a)(2)(F) of the CAA

N

(i)(1)(i)-(ii)	Did the State, by November 29, 1999, identify in writing
to the FLMs the title of the official to which any FLM can submit
recommendations on the implementation 51.308 including, (i)
identification of impairment of visibility in any Class I area(s); and
(ii) identification of elements for inclusion in the visibility
monitoring strategy required by §51.305 and 51.308?

 p. 35747-48 of the 1999 RHR



Y

(i)(2)	Did the State provide the FLM an opportunity for consultation, in
person and at least 60 days prior to holding any public hearing on the
SIP (or its revision)?	Subsection 3.2,    Part 3.2.3	 p. 35747-48 of the
1999 RHR



Y

(i)(2)(i)-(ii)	Did the above consultation include the opportunity for
the FLMs to discuss their: (i) assessment of impairment of visibility in
any Class I area; and, (ii) recommendations on the development of the
RPG and on the development and implementation of strategies to address
visibility impairment?	Subsection 3.2,    Part 3.2.3	 p. 35747-48 of the
1999 RHR



Y

(i)(3)	Did the State include in the SIP a description of how it
addressed any comments provided by the FLMs?	(Response will follow.)	 p.
35747-48 of the 1999 RHR



Y

(i)(4)	Does the SIP provide procedures for continuing consultation
between the State and FLMs on the implementation of 51.308, including
development and review of SIP revisions and 5-year progress reports, and
on the implementation of other programs having the potential to
contribute to impairment of visibility in Class I areas?	Subsection 3.2,
   Part 3.2.3	 p. 35747-48 of the 1999 RHR





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EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

8/4/06 

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EPA Checklist for Regional Haze SIPs Submitted Under 40 CFR 51.308

8/04/06 

