Comprehensive Visibility Protection Program for Class 1 Areas
Trinity Consultants worked extensively with clients during the first Regional Haze planning period (2004-2018), which included Best Available Retrofit Technology (BART) and Reasonable Progress (RP) analyses, litigation support across the U.S., and numerous strategy discussions and negotiations with states, EPA and Federal Land Managers. From this experience, we recommend industrial sites be involved in the stakeholder process for the second and future planning periods (2019-2028, 2029-2038, and so on), and ensure the performance of the following steps. Trinity can provide guidance for your site(s) through this process:
- Analyze Interagency Monitoring of Protected Visual Environments (IMPROVE) data by species to determine impact per species on Class 1 Area
- Compare actual visibility impairment as measured for a Class 1 Area to the Uniform Rate of Progress (URP) or "glidepath"
- Determine source contribution to impairment by type
- Assess impact of international sources on Class 1 areas
- Assess individual source contributions and test alternative emission rates
- Conduct Four-Factor Analyses, including control cost evaluations
For those sites located in areas managed by Regional Planning Organizations (RPOs) and in states that have not defined their screening methodology, Trinity can assist with this analysis to determine if your site might be screened into this program, or we can help you be more prepared in the stakeholder process and subsequent evaluation phase. We can advise on recent EPA guidance on issues such as where options may exist for optimizing modeling and what steps the regulated community may want to take now as the states decide about NOx, SO2, and PM10 control measures for the next ten years.
What is the Regional Haze Rule?
The Regional Haze Rule (RHR) establishes a comprehensive visibility protection program for certain national and international parks and wilderness areas ( Class 1 areas) and requires states to set reasonable progress goals (RPGs) towards achieving natural visibility conditions in all Class 1 areas by 2064. EPA released Regional Haze Rule Technical Guidance on Tracking Visibility Progress for the Second Implementation Period outlining the methods by which states should develop their State Implementation Plans (SIPs) for the 2nd planning period (2018-2028). The guidance includes methods previously not allowed in the 1st planning period.
On August 20, 2019, EPA published a final memorandum for Guidance on Regional Haze State Implementation Plans for the Second Implementation Period. This guidance provides additional insight for states as they select sources to evaluate for potential additional control based on the four statutory factors listed in 40 CFR 51.308(f)(2)(i): cost of compliance, time necessary for compliance, energy and non-air environmental impacts, and remaining useful life of the source. Additional factors, including the visibility benefits of controls, may also be considered in these evaluations.
Important Dates: 2nd Planning Period Overview
July 31, 2021 - SIPs are due for the 2nd planning period. The SIPs should include a state's calculations of baseline and natural visibility conditions, including scientific data documenting an adjustment to the URP if international emissions impact a state's Class 1 area(s), the long-term strategy for regional haze reduction, and RPGs to achieve natural conditions by 2064. Unlike the 1st planning period, where Best Available Retrofit Technology (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.
There are five regional planning organizations (RPOs) that evaluate technical information related to how their States and Tribes impact Class 1 areas. RPOs are developing proposed methodologies for screening sources to determine whether sources could potentially impact a Class 1 area. The data collected and methodologies proposed are then passed to states for their SIP development.
Software Expertise for Regional Haze
Trinity has performed regional haze analyses for Best Available Retrofit Technology (BART) and Reasonable Progress (RP) evaluations in support of the Regional Haze Rule with the CAMx photochemical model. For the 2nd planning period, photochemical modeling has gained favor and is recommended by EPA because of its superior consideration of chemical reactivity as well as other options. We are also versed in the use of the SCICHEM and CMAQ models.
Download Presentation PDF - Use Of Camx In Evaluating Impacts For The Regional Haze Rule -- 2017
Trinity Can Help - Contact Us Today
Is the 2nd planning period evolves, Trinity will continue to follow the RPOs/states to remain current with developments. For more information, contact Trinity at (800) 229-6655 for assistance in determining what your RPO/state is planning, helping to decipher RPO methodologies and how they may impact your site, preparing comments on proposed methodologies and photochemical modeling, and conducting site-specific evaluations.
- Download presentation PDF - Regional Haze for the Rest of the United States - Building off WRAP Analyses
Related articles for more information:
- Oregon - Oregon DEQ has Published Significant Sources for Regional Haze Planning -- Jan 24, 2020
- Four-Factor Source Analysis: Guidance on Regional Haze SIPs for the Second Implementation Period -- Oct 17, 2019
- Utah - Utah Finishes 1st Planning Period SIP and Prepares for 2nd Planning Period -- Jul 25, 2019
- Will You Be Targeted for the Regional Haze Second Planning Period? -- May 09, 2019
- Power Targets for the Regional Haze Second Planning Period -- Apr 30, 2019
- Oil and Gas Potential Targets for the Regional Haze Second Planning Period -- Apr 30, 2019
- Regional Haze Rule Second Planning Period -- Apr 19, 2019
- Iowa - Regional Haze and Prong 4 SIP Revisions -- Apr 24, 2019
- Montana - Montana CAAAC Meeting Updates -- Feb 27, 2019
- Oklahoma - Strategy for the Regional Haze Rule 2nd Planning Period -- Feb 19, 2019
- Alabama - Proposed Rule: Air Plan Approval; Regional Haze Progress Report -- Jan 08, 2019
- Arizona - Regional Haze Updates -- Nov 02, 2018
- Complimentary Webinar - Regional Haze 2nd Planning Period - General Overview
- Regional Haze 2nd Planning Period in the WRAP Region - Part 1: General Overview
- Complimentary Webinar - In Association with Alpine Geophysics - Regional Haze 2nd Planning Period in the WRAP Region - Part 2 State Specific Updates ad Q&A