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DAQ Home > 2011 SIP Proposal > Comparison of Requirements and Issues

Table 1: Comparison of Requirements and Issues
for Possible Paths for Utah’s Regional Haze SIP

 

A.  308 Utah Stand-Alone SIP
B.  308 Utah SIP
in Regional Partnership (WRAP)
C.  309 GCVTC SIP
D.  309 GCVTC SIP W/All Class I 
Areas Addressed in 2003
 
Geographic Scope (Class I Areas to be Addressed)

5 in Utah + others outside Utah affected by Utah emissions

308(d)

5 in Utah + others outside Utah affected by Utah emissions

308(d)

2003:  16 GCVTC Class I areas (5 in Utah)

309(b)(1)

2008:  Others outside Utah affected by Utah emissions

309(g)

2003: 16 GCVTC Class I areas (5 in Utah) + all Others required under Option C.

309(b)(1) and 309(g)

Anticipated SIP Due Dates (Assumptions)

2005:  Complete SIP with long-term strategy and demonstration of reasonable progress

308(b)(1)

(Based on assumption that Utah will not have a nonattainment area for PM2.5 in 2004.  If Utah does have a PM2.5 nonattainment area, then the timeline follows Option B.)

2005:  Regional Planning commitment

308(c)(1)

2007:  Complete SIP with long-term strategy and demonstration of reasonable progress

308(c)(2), 308(b)(2)

(Based on assumption that Utah joins a regional planning organization (WRAP) and some other member state has nonattainment area for PM2.5 by 2005.)

2003:  December 31, 2003, for 16  GCVTC Class I areas (5 in Utah).

309(c)

2008:  December 31, 2008, for all Other Class I areas.

309(g)(2)

2003:  December 31, 2003, with SIP covering all areas.

309(c)

SIP Applicable Period and Progress Report Due Dates

Through 2018 or 11 years  (Covers requirements from 2007 to 2018.)

Progress report due in 2010, 2015

308(g)

Next SIP cycle by 2018

308(f)

Through 2018 or 11 years  (Covers requirements from 2007 to 2018.)

Progress report due in 2010, 2015

308(g)

Next SIP cycle by 2018

308(f)

Through 2018 or 15 years, for GCVTC Class I areas.  10 years for Other Class Is. 

 

Progress report due in 2008, 2013, 2018

309(d)(10)

Next SIP cycle by 2018

309(d)(1) and 309(d)(10)

Through 2018 or 15 years for all Class I areas.

Progress reports due in 2008, 2013, 2018.

309(d)(10)

Next SIP cycle 2018

309(d)(1) and 309(d)(10)

Baseline Visibility Conditions

Must establish Baseline visibility conditions for Class I areas based on 2000-2004 data.

308(d)(2)

Must establish Baseline visibility conditions for Class I areas based on 2000-2004 data.

308(d)(2)

2003:  Not required for 16 GCVTC Class I areas.

309(d)(2)

2008:  Must establish Baseline visibility conditions for Other Class I areas based on 2000-2004 data.

309(g)(3) and 308(d)(2)

2003:  Not required for 16 GCVTC Class I areas.

309 (d)(2)

Also 2003:  Must establish Baseline visibility conditions for Other Class I areas based on most recent 5 years of data.

 309(g)(3) and 308(d)(2)

Estimated Natural Conditions

Must estimate Natural Conditions at Class I areas for use in 60-year glide path analysis.

308(d)(2)

Must estimate Natural Conditions at Class I areas for use in 60-year glide path analysis.

308(d)(2)

2003:  Not required for 16 GCVTC Class I areas

309(d)(2)

2008:  Must estimate Natural Conditions at Other Class I areas for use in 60-year glide path analysis.

309(g)(3) and 308(d)(2)

2003:  Not required for 16 GCVTC Class I areas

309(d)(2)

Must estimate Natural Conditions at Other Class I areas for use in 60-year glide path analysis.

309(g)(3) and 308(d)(2)

Reasonable Progress Goal

Must establish Reasonable Progress Goal (in deciviews) for all Class I areas.  Analysis must consider 60-year glide path alternative, improvements from current programs, and the final Long Term strategy submitted.

308(d)(1)

Must establish Reasonable Progress Goal (in deciviews) for all Class I areas.  Analysis must consider 60-year glide path alternative, improvements from current programs, and the final Long Term strategy submitted.

308(d)(1)

2003:  Not required for 16 GCVTC Class I areas, although projections of improvements from Long Term Strategy are required.

309(d)(2)

2008:  Must establish Reasonable Progress Goal (in Deciviews) for Other Class I areas. 

309(g)(3) and 308(d)(1)

2003:  Not required for 16 GCVTC Class I areas, although projections of improvements from Long Term Strategy are required.

309(d)(2)

2008:  Must establish Reasonable Progress Goal (in Deciviews) for Other Class I areas. 

309(g)(3) and 308(d)(1)

Reasonable Progress Goal: Consultation

Consultation required between states, FLM’s on final goal selected and apportionment of emission reduction contributions to achieve reasonable progress goal. 

308(d)(1)(iv), 308(i)(2)

Consultation required between states, FLM’s on final goal selected and apportionment of emission reduction contributions to achieve reasonable progress goal. 

308(d)(1)(iv), 308(i)(2)

2003:  WRAP coordination of Modeling Demonstration will satisfy need for 16 GCVTC Class I areas.

309(d)(2)

2008:  Consultation required between states, FLM’s on final goal selected and apportionment of emission reduction contributions to achieve reasonable progress goal for Other Class I areas 

309(g)(3), 308(d)(1)(iv)

2003:  WRAP coordination of Modeling Demonstration will satisfy need for 16 GCVTC Class I areas.

309(d)(2)

Also 2003:  Consultation required between states, FLM’s on final goal selected and apportionment of emission reduction contributions to achieve reasonable progress goal for Other Class I areas 

309(g)(3), 308(d)(1)(iv)

Long-Term Strategy Development Process
(Note:  Requirements specific to each source sector are found in Table 2.)

Must examine controls available to achieve 60-year glide path improvement for all source categories.  Through extensive stakeholder process, must identify the control strategy components that will collectively make “Reasonable Progress.”  Plan must include all required measures for attainment and maintenance plans.

308(d)(3)

(Note:  May use strategy components developed by WRAP as part of the overall plan.)

Must examine controls available to achieve 60-year glide path improvement for all source categories.  Through extensive stakeholder process, must identify the control strategy components that will collectively make “Reasonable Progress.”  Plan must include all required measures for attainment and maintenance plans.

308(d)(3)

Plan must address regional  strategies developed by Regional Planning Organization (WRAP.)

308(c)(1)(iv)

2003:  Long Term Strategy must include provisions to address variety of source categories as outlined in 309(d)(4-9) (e.g., stationary sources, mobile sources, programs related to fire, area sources of dust emissions from paved and unpaved roads, pollution prevention and other GCVTC measures.)

309(d)(4 thru 9)

2008:  Other Class I areas would be addressed in a manner similar in scope to the 308 process, except the state can rely on 2003 GCVTC Long Term Strategy as a starting point to build upon.

309(g)(3-4), 308(d)3)

2003:  Long Term Strategy must include provisions to address variety of source categories as outlined in 309(d)(4-9) (e.g., stationary sources, mobile sources, programs related to fire, area sources of dust emissions from paved and unpaved roads, pollution prevention and other GCVTC measures.)

309(d)(4 thru 9)

Also 2003:  Other Class I areas would be addressed in a manner similar in scope to the 308 process, except the state can rely on 2003 GCVTC Long Term Strategy as a starting point to build upon.

309(g)(3-4), 308(d)3)

Modeling Demonstration

Modeling demonstration required of Long Term Strategy for all affected Class I areas and for all sources inside and outside the state.  Must include consideration of other states’ SIP long Term strategies.  May be able to use WRAP resources as a starting point.

 308(d)(3)(ii)

Modeling demonstration required of Long Term Strategy for all affected Class I areas and for all sources inside and outside the state.  Must include consideration of other states’ SIP long Term strategies.  May be able to use WRAP resources as a starting point.

2003:  Demonstration required of Long Term Strategy relies on WRAP technical assessments.

309(d)(2)

2008: Demonstration required of Long Term Strategy for Other Class I areas relies on WRAP technical assessments.

309(g)(3) and 308(d)(3)(ii)

2003:  Demonstration required of Long Term Strategy relies on WRAP technical assessments.

309(d)(2)

2008: Demonstration required of Long Term Strategy for Other Class I areas relies on WRAP technical assessments.

309(g)(3) and 308(d)(3)(ii)

Reasonable Progress Demonstration

Requires analysis of 60-year glide path to natural conditions, and justification that proposed Long Term Strategy makes “reasonable progress” based on visibility improvement, cost, and other factors.

308(d)(1 )

Note:  2018 SIP requires same analysis except from “then current conditions” to natural conditions in  2064.

Requires analysis of 60-year glide path to natural conditions, and justification that proposed Long Term Strategy makes “reasonable progress” based on visibility improvement, cost, and other factors.

308(d)(1)

Note:  2018 SIP requires same analysis except from “then current conditions” to natural conditions in  2064.

2003:  Requires demonstration that SIP contains GCVTC control programs.                   309(a)

2008:  Other Class I areas: similar to Options A and B, except that Long Term Strategy from 2003 should be the basis.

309(g)

Note:  2018 SIP must be developed under 308 with the same requirements as Options A or B.  As in 308, glide path would be from the then “current” visibility conditions to natural conditions in 2064. 

2003:  Requires demonstration that SIP contains GCVTC control programs.                    309(a)

Also 2003:  Other Class I areas: similar to Options A and B, except that Long Term Strategy from 2003 should be the basis.

309(g)

Note:  2018 SIP must be developed under 308 with the same requirements as Options A or B.  As in 308, glide path would be from the then “current” visibility conditions to natural conditions in 2064.  

5-Year Progress Report Needs to Address Reasonable Progress Goals

Yes.  For all Class I areas.  SIP must be adjusted for shortfall in achieving improvement goal if needed.

308(g)(6), 308(h)(4)

Yes.  For all Class I areas.  SIP must be adjusted for shortfall in achieving improvement goal if needed.

308(g)(6), 308(h)(4)

No, for 16 GCVTC areas.

Yes, for Other Class I areas.  SIP must be adjusted for shortfall in achieving goal improvement if needed.

309(d)(10)(i)(F), 309(d)(10)(ii)(D)

No, for 16 GCVTC areas.

Yes, for Other Class I areas.  SIP must be adjusted for shortfall in achieving goal improvement if needed.

309(d)(10)(i)(F), 309(d)(10)(ii)(D)

Monitoring and Reporting

Monitoring and reporting of emissions and visibility required.  Could rely on WRAP for assistance in progress reports.

308(d)(4), 308(g)

Monitoring and reporting of emissions and visibility required.  Could rely on WRAP for assistance in progress reports.

308(d)(4), 308(g)

Monitoring and reporting of emissions and visibility required.  Would rely on WRAP for assistance in progress reports.  Reporting and tracking may be more comprehensive for some source categories.

309(d)(3 - 7), 309(d)(10)

Monitoring and reporting of emissions and visibility required.  Would rely on WRAP for assistance in progress reports.  Reporting and tracking may be more comprehensive for some source categories.

309(d)(3 - 7), 309(d)(10)

Best Available Retrofit Technology (BART) for Sulfur Dioxide (SO 2)

Must be addressed in 2005 SIP.

308(e)

Source-specific BART must be implemented by 2010.

308(e)(1)(v)

Alternatively may use “Market Program” if greater reasonable progress can be shown by 2018.

308(e)(2)

(Note:  Could opt into the WRAP Market Trading Program.) 

2003:  Submit list of sources

308(c)(1)(v)

2007:  Must address emission limitations.

308(e)

Source specific BART must be implemented by 2012.

308(e)(1)(v)

Alternatively may use “Market Program” if greater reasonable progress can be shown by 2018.

308(e)(2)

(Note:  Could opt into the WRAP Market Trading Program.) 

2003:  Must be addressed with analysis and demonstration that emission milestones/backstop trading program makes greater reasonable progress that BART.

309(f)(1)(i)

2008:  Must show emission milestones/backstop trading program is reasonable progress for Other Class I areas or adjust milestones accordingly.

309(g)(4)(ii), 308(e)2)

2003:  Must be addressed with analysis and demonstration that emission milestones/backstop trading program makes greater reasonable progress that BART.               309(f)(1)(i)

Also 2003:  Other Class I areas would require a demonstration that emission milestone/backstop trading program would make greater reasonable progress that BART, and would satisfy overall reasonable progress for these areas.

309(g)(4)(ii, 309(g), 309(e)(2)

(Note:  Would eliminate the potential for adjustment in milestones from Option C.)

BART for Oxides of Nitrogen (NOx) and Particulate Matter (PM)

Must be addressed in 2005 SIP

308(e)

Source specific BART must be implemented by 2010.

308(e)(1)(v)

Alternately may use Market Program if greater reasonable progress can be shown by 2018.

308(e)(2)

2005:  Submit list of sources.

308(c)(i)(v)

2007:  Must address emission limitations.                

308(e)

Source specific BART must be implemented by 2012.

308(e)(1)(v)

Alternately may use Market Program if greater reasonable progress can be shown by 2018.

308(e)(2)

2003:  Report assessing emission control strategies for NOx and PM.      309(d)(4)(v)

2008:  SIP revision to address NOx and PM strategies and BART.                309(d)(4)(v)

Source specific BART must be implemented by 2013.

308(e)(1)(v)

Or may use Market Trading program if greater reasonable progress is shown by 2018.

309(g)(4)(ii), 308(e)(2)

2003:  Report assessing emission control strategies for NOx and PM.     309(d)(4)(v)

2008:  SIP revision to address NOx and PM strategies and BART.                309(d)(4)(v)

Source specific BART must be implemented by 2013.

308(e)(1)(v)

Or may use Market Trading program is greater reasonable progress is shown by 2018.

309(g)(4)(ii), 308(e)(2)

Clean Air Corridors

Not explicitly addressed in 308, but emissions monitoring and reporting is required in Progress Reports.  However, Long Term Strategy must address protection of best 20% reasonable progress goal.

308(d)(1)

Not explicitly addressed in 308, but emissions monitoring and reporting is required in Progress Reports.  However, Long Term Strategy must address protection of best 20% reasonable progress goal.

308(d)(1)

2003:  For 16 GCVTC Class I areas, SIP must identify areas considered to be Clean Air Corridors and establish emissions tracking program.  If significant emission increases occur that could impair visibility on the 20% cleanest days, then the Long Range strategy would need to be updated. 

309(d)(3)

2003:  For 16 GCVTC Class I areas, SIP must identify areas considered to be Clean Air Corridors and establish emissions tracking program.  If significant emission increases occur that could impair visibility on the 20% cleanest days, then the Long Range strategy would need to be updated. 

309(d)(3)

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