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The 2nd Planning Period for Regional Haze has started and requires states to examine all sources regardless of type and potential impacts on visibility and prepare Regional Haze SIPs by July 2021. To assist with the 2nd Planning Period, EPA released the Regional Haze Reform Roadmap on September 11, 2018 outlining a path for EPA to work collaboratively with states to implement the Regional Haze Rule (RHR).1 Then on December 20, 2018, EPA released Technical Guidance for the 2nd planning period including several key items that differ from the 1st planning period.

The Guidance also redefines visibility impairment with no de minimis threshold of impact and requires photochemical grid modeling (PGM) for visibility assessments. Unlike the 1st planning period, where BART-subject sources were the focus, the 2nd planning period can target any large source of NOx, SO2, and/or PM across industries, including sources previously evaluated under BART. Each Regional Planning Organization (RPO) and state must develop a targeted plan, which may vary across RPOs and eventually states including source screening and four-factor analyses. For a more detailed summary of the Regional Haze Second Planning Period, Trinity will be issuing an Environmental Quarterly in May 2019. If you are not currently receiving EQ's, please subscribe today.

At the time of this article, the Western Regional Air Planning (WRAP) RPO has released its methodology for the 2nd Planning Period and the timeline for the assessment. Therefore, if your facility is located in WRAP, it is recommended that you contact your local Trinity office for assistance.

Other RPOs/states are still in the beginning phase. As the 2nd planning period continues to evolve, Trinity will continue to follow the RPOs/states to stay up to date on the latest developments. In the meantime, if you are interested in discussing this topic or want to find out more specifics about your area, please contact your local Trinity office at (800) 229-6655 for assistance.

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1 U.S. EPA, Office of the Administrator. Re: Regional Haze Reform Roadmap (September 11, 2018).