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Other Considerations in Resubmitting the 309 SIPs

Other Considerations in Resubmitting the 309 SIPs. Applicable to AZ, NM, OR, UT, WY And Bernalillo County, NM. SO2 Backstop Trading Program. Milestones Recalculate 2018 milestone Establish interim milestones and setasides Better-than-BART demonstration Emission comparison may suffice

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Other Considerations in Resubmitting the 309 SIPs

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  1. Other Considerations in Resubmitting the 309 SIPs Applicable to AZ, NM, OR, UT, WY And Bernalillo County, NM

  2. SO2 Backstop Trading Program • Milestones • Recalculate 2018 milestone • Establish interim milestones and setasides • Better-than-BART demonstration • Emission comparison may suffice • A 2002 “crticial mass” study by ICF estimated that only 10-20% of point source emissions would be traded across state lines in a 5-state scenario • Since then, reductions initiated in 4 of the 5 states • Hence, modeling to address geographic impact of BART vs the backstop may be unnecessary

  3. SO2 Backstop Trading Program • WRAP Model Rule • Revisions necessary for AZ, potentially helpful to other states • Revise penalty provisions • Clarify allowance allocations • Incorporate revised milestones • Emission methodology • SIP must document the specific methodology used to calculate SO2 emissions during the base year for each emitting unit

  4. Other 309 Elements • NOx and PM for stationary sources • Essentially BART • Miscellaneous reports due in 2013 • Pollution prevention • Clean air corridors • Mobile source trends • Visibility modeling projections for the 16 areas

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