Update on theUpdate on theSTIP-II Project:STIP-II Project:

Draft Model SIPDraft Model SIP

Brian FinneranBrian Finneran

Oregon Department of Environmental QualityOregon Department of Environmental Quality

WRAP Air Manager’s CommitteeWRAP Air Manager’s Committee

Santa Fe, NMSanta Fe, NM

March 19, 2003March 19, 2003

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STIP-2 OverviewSTIP-2 Overview

STIP = SIP + TIPSTIP = SIP + TIP

Objective:Objective: Create a model plan or Create a model plan or “working template” for States & Tribes to “working template” for States & Tribes to use for preparing Regional Haze SIPs and use for preparing Regional Haze SIPs and TIPs for Section 309.TIPs for Section 309.

Based on the SIP/TIP Template developed Based on the SIP/TIP Template developed by WESTAR in 2000.by WESTAR in 2000.

Last project update - WRAP Board meeting Last project update - WRAP Board meeting Tempe, AZ on 11/13/02Tempe, AZ on 11/13/02

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Project SummaryProject Summary

STIP-2 Project consists of 2 distinct parts:STIP-2 Project consists of 2 distinct parts:

a a Model SIPModel SIP – to help states meet the – to help states meet the 12/31/03 deadline under 309.12/31/03 deadline under 309.

a a Model TIPModel TIP – to help tribes that elect – to help tribes that elect to adopt a 309 TIP.to adopt a 309 TIP.

Both Model SIP & Model TIP reviewed by Both Model SIP & Model TIP reviewed by the STIP-2 Working Group.the STIP-2 Working Group.

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Project Participants Project Participants

Model SIP author – Brian FinneranModel SIP author – Brian Finneran, , Oregon DEQ. Oregon DEQ.

Model TIP author – Rosanne SanchezModel TIP author – Rosanne Sanchez, , New Mexico Environment Department. New Mexico Environment Department.

TSD project assistance – Tom MooreTSD project assistance – Tom Moore, , WRAPWRAP

STIP-2 Working Group – 18 membersSTIP-2 Working Group – 18 members: : 5 States, 3 tribal reps, 4 EPA, 2 NTEC, 5 States, 3 tribal reps, 4 EPA, 2 NTEC, 2 WESTAR, & 2 WRAP.2 WESTAR, & 2 WRAP.

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Project Timetable Project Timetable

One-year project – Started 10/02One-year project – Started 10/02

Model SIPModel SIP::

Draft developed 11/2002 to 3/2003Draft developed 11/2002 to 3/2003

Draft submitted 3/11/03Draft submitted 3/11/03

Now open for comment/review Now open for comment/review

Final Model SIP: Soon! (depends on review)Final Model SIP: Soon! (depends on review)

Model TIPModel TIP::

Draft underway, est. completion 5/2003Draft underway, est. completion 5/2003

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Future Model SIP work Future Model SIP work

Model SIP to be used by State of Oregon Model SIP to be used by State of Oregon after completion for developing 309 SIP after completion for developing 309 SIP (May–July).(May–July).

Model SIP follow up – address any Model SIP follow up – address any outstanding issues, assist other states, outstanding issues, assist other states, assist & coordinate with Model TIP, TSD assist & coordinate with Model TIP, TSD project.project.

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““Guiding Principles” for Guiding Principles” for Model SIP/TIP Model SIP/TIP

In addition to a “working template”, needs to In addition to a “working template”, needs to be a “how to” guide for preparing 309 be a “how to” guide for preparing 309 SIP/TIP.SIP/TIP.

Identify all applicable TSD needed for 309 Identify all applicable TSD needed for 309 SIP, and how/where to incorporate it.SIP, and how/where to incorporate it.

Identify and describe all applicable WRAP Identify and describe all applicable WRAP Policies & Guidance developed for 309. Policies & Guidance developed for 309.

Explain to EPA how TSD and WRAP Policies Explain to EPA how TSD and WRAP Policies would be used by states to meet each 309 would be used by states to meet each 309 requirement.requirement.

Meet EPA criteria for SIP/TIP approvability.Meet EPA criteria for SIP/TIP approvability.

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Development of Model SIP Development of Model SIP

Nov 2003. STIP Working Group members Nov 2003. STIP Working Group members identified. EPA role expanded to include identified. EPA role expanded to include Regions 6, 8, 9 and 10. Regions 6, 8, 9 and 10.

Held four STIP Working Group conference Held four STIP Working Group conference calls Dec 2002 – March 2003.calls Dec 2002 – March 2003.

Scope of project expanded end of Jan 2003 Scope of project expanded end of Jan 2003 in response to EPA member comments in response to EPA member comments (more discussion needed on how states will (more discussion needed on how states will meet each rule, and description of all meet each rule, and description of all applicable TSD & WRAP applicable TSD & WRAP policies/documents).policies/documents).

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Model SIP Table of Contents Model SIP Table of Contents

I.I. Exec. Summary – describes Model SIP, Exec. Summary – describes Model SIP, Model TIP, & TSD project.Model TIP, & TSD project.

II.II. Background – Clean Air Act, GCVTC Background – Clean Air Act, GCVTC Recommendations, & WRAP overview.Recommendations, & WRAP overview.

III.III. 12 Chapters – for each 309 Rule 12 Chapters – for each 309 Rule Requirement.Requirement.

IV.IV. Master List of Appendices from each Master List of Appendices from each chapter, list of RHR definitions, & EPA chapter, list of RHR definitions, & EPA Completeness Criteria for SIPs.Completeness Criteria for SIPs.

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Model SIP Chapters Model SIP Chapters

A.A. Projection of Visibility ImprovementProjection of Visibility Improvement

B.B. Clean Air CorridorsClean Air Corridors

C.C. Stationary SourcesStationary Sources

D.D. Mobile SourcesMobile Sources

E.E. Fire ProgramsFire Programs

F.F. Paved & Unpaved Road DustPaved & Unpaved Road Dust

G.G. Pollution PreventionPollution Prevention

H.H. Additional GCVTC RecommendationsAdditional GCVTC Recommendations

I.I. Periodic Implementation Plan RevisionsPeriodic Implementation Plan Revisions

J.J. State Planning/Interstate Coordination & Tribal State Planning/Interstate Coordination & Tribal ImplementationImplementation

K.K. Geographic EnhancementsGeographic Enhancements

L.L. Reasonable Progress for Additional Class I AreasReasonable Progress for Additional Class I Areas

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Each Chapter contains four sections:Each Chapter contains four sections:

1.1. Actual 309 Rule Language.Actual 309 Rule Language.

2.2. General description of rule requirement, General description of rule requirement, and how state intends to meet the rule.and how state intends to meet the rule.

3.3. Template language to use in the SIP.Template language to use in the SIP.

4.4. Summary of all applicable WRAP technical Summary of all applicable WRAP technical reports (TSD) and Policies/Documents.reports (TSD) and Policies/Documents.

Model SIP Chapters/Sections Model SIP Chapters/Sections

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K. Geographic Enhancements

1. Regulatory Language

51.309(f)(4) Geographic Enhancement. In accordance with the provisions under paragraph (f)(1) of this section, the annex may include a geographic enhancement to the program provided for in paragraph (d)(4) of this section to address the requirement under § 51.302(c) related to Best Available Retrofit Technology for reasonably attributable impairment from the pollutants covered by the milestones or the backstop market trading program.

2. General Discussion of Rule Requirement

The requirements for geographic enhancement are discussed on page 35757 in the Preamble to the RHR. These requirements are related to Section 51.309(f)(1) which describe requirements for the Annex. The Annex allows states to submit a SIP, or tribes a TIP, which adopts an alternative measure to regional haze BART. Geographic enhancement is a voluntary approach that can be included in the Annex for addressing reasonably attributable (RA) BART for stationary sources, under the provisions of Section 51.302(c). RA BART is different from regional haze BART,

3. Template Language

Geographic Enhancement. (a)Procedure for addressing Reasonably Attributable BART under the Regional Haze Rule. Pursuant to 40 CFR 51.309(f)(4), the State of [name] shall rely upon the geographic enhancement provisions contained in the Annex for the purposes of addressing reasonably attributable impairment in any Class I area, and the need for Best Available Retrofit Technology, as specified in 40 CFR § 302(c).

4. Applicable WRAP Reports and Documents The WRAP Market Trading Forum has developed a Memorandum of

Agreement (MOA) between federal land managers and states to address reasonably attributable BART. PLACEHOLDER – MOA still being developed, will provide further description when completed.

Example of Example of Model SIP Model SIP Chapter Chapter

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Section 3 Template Language Section 3 Template Language

Legal ref: “Pursuant to 40 CFR 51.309(f)(4)”Legal ref: “Pursuant to 40 CFR 51.309(f)(4)”

““The State of [name] shall…”The State of [name] shall…”

Template section identifies & summarizes all Template section identifies & summarizes all control strategies, SIP commitments and control strategies, SIP commitments and implementation schedules. implementation schedules.

Extensive use of appendices – detailed Extensive use of appendices – detailed information should go into an appendix to information should go into an appendix to the SIP. (22 references to appendices) the SIP. (22 references to appendices)

““Master List of Appendices” in back of Master List of Appendices” in back of document, summarizes what each appendix document, summarizes what each appendix needs to contain. needs to contain.

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Conclusion – Feedback NeededConclusion – Feedback NeededOpen for AMC, Planning Team review Open for AMC, Planning Team review

Suggested focus:Suggested focus:

1.1. Template Sections – are all regulatory bases Template Sections – are all regulatory bases covered, language acceptable to states?covered, language acceptable to states?

2.2. Stationary Source and Fire chapters – these Stationary Source and Fire chapters – these contain the most information, need close contain the most information, need close review by WRAP.review by WRAP.

3.3. Master List of Appendices – does summary of Master List of Appendices – does summary of each appendix cover everything? each appendix cover everything?

Note: Note: “Placeholder” in Mobile Source chapter “Placeholder” in Mobile Source chapter tied to outcome of resolution of mobile source tied to outcome of resolution of mobile source significance issue.significance issue.

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Questions??Questions??

Comments??Comments??