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Proposed Reasonable Progress Rule Workshop

On August 1, 2007, a second public workshop was held in Tallahassee, Florida to address proposed changes to compliance deadlines and selection criteria related to visibility impact regulations. Key discussions included extending the permit application deadlines, modifying criteria for significant contribution, and eliminating unnecessary documents while justifying selection thresholds. New selection criteria were proposed based on emissions data, aiming to ensure that the largest contributors to visibility impairment are accurately reviewed. Feedback from the initial workshop emphasized the need for clarity and justification in the regulatory framework.

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Proposed Reasonable Progress Rule Workshop

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  1. Proposed Reasonable Progress Rule Workshop Second Public Workshop August 1, 2007 Tallahassee, Florida

  2. Comments From 1st Workshop • Extend the permit application deadline (April 30, 2008, Dec 31, 2008) • Extended to September 30, 2008 • Change the compliance deadline date (Dec 31, 2017) • Extended to December 31, 2014 • Increase significant contribution threshold (1%) • Considered, developed new criteria • Allow consideration of visibility impact • Changed rule language to reflect visibility impact analysis not required

  3. Comments From 1st Workshop (cont.) • Take out the “responsibility to comply” applicability statement • Retained – makes sense with new selection criteria • Produce area of influence document • Document no longer necessary with new selection criteria • “Reasonable progress” already made, no additional reductions needed • Reasonable progress only determined after four-factor analysis – state cannot bypass this requirement

  4. Comments From 1st Workshop (cont.) • Provide justification for selection of various thresholds or cutpoints • Provided at this workshop • Change BART-equivalent determination submittal application deadline to coincide with the RP application • Extended deadline to June 30, 2008 – still does not coincide with application

  5. Jun 14 Proposed Selection Criteria • Selection based on modified Georgia criteria with RTmax*Q/d: • VISTAS residence time data (within 5% for EGU’s and 10% non-EGU’s) • 2002 actual emissions (units > 250 tpy) • >= 0.5% unit contribution, considering only Florida units • Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

  6. Considered Changes to Selection Based on Comments • Increase contribution threshold from 0.5% to 1% • Include units in all states to determine contribution • Take out EGU/non-EGU selection criterion based on RTMax • See handout for results

  7. Considerations for Changing to a Q/d Selection Criteria • The inclusion of residence time (RTMax), while logical, is somewhat complicated, and when used with Q/d to develop a relative contribution surrogate at each Class I area, results in some seemingly illogical conclusions. • The use of Q/d alone as a surrogate for visibility impact is easy to understand and produces a similar selection of sources as does a Q/d*RTMax relative contribution criterion.

  8. Proposed New Selection Criteria • All SO2 units having >= 250 tpy (2002 actual) and having an emissions Q (tons) to distance d (km) ratio of 50 or greater. • Selection based on each Class I area potentially affected by Florida sources (EVER,CHAS,SAMA,OKEF,WOLF,BRET)

  9. Why Q/d >= 50? • Selection of sources close to those under the 1% Q/d*RTMax criteria. • Q/d of 50 is five times the exemption threshold used for BART. Provides that sources selected are important contributors to visibility impairment. • Recognize that visibility improvement at the Class I areas in or near Florida is projected to be near the uniform rate of progress, thus justifying selection of only the largest sources for four-factor review.

  10. Sources Selected Under the Q/d Criteria

  11. Sources Selected Under the Q/d Criteria

  12. Comparison of Selection Criteria

  13. Some Statistics • The 15 facilities included comprise ~⅔ of the total stationary point source SO2 emissions that occurred in 2002. • In rank order, these 15 facilities comprise the 1,2,3,4,5,6,7,8,9,15,18,19,26, and 30 largest facilities in the state as of 2002.

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