Spring Business Meeting

1

• Spring Business Meeting
• Regional Haze SIP Development Survey
• San Francisco, California
• April 9, 2003

2
PLANNING COMMITTEESurvey to Evaluate
Resources Necessary to Develop a Regional Haze
Control PlanBob Habeck Montana DEQ
3
OBJECTIVES

• Planning Committee recommendation to Council
• - Summarize survey results and conclusions.
• - Discuss potential issues.
• - Discuss distribution process.
• - Seek Air Director approval.

4
PURPOSE OF SURVEY

• To Determine State Resources Needed to Prepare,
  Review, Approve, and Implement Regional Haze
  Visibility Control Plans1.
• 1Source November 7, 2001 letter to EPA Assistant
  Administrator Jeff Holmstead. WESTAR committed
  to preparing a report addressing this topic.

5
SURVEY RATIONALE

• Results to be used by states in deciding between
  308 and 309 strategies.
• Results to be use when working with EPA on SIP
  preparation, funding, and implementation issues.
• Results to be useful to WRAP committees to assist
  in prioritizing products that states are
  depending upon for SIP development.

6
SURVEY TIMELINE

• Survey completed August 2002.
• Received responses from 15 states one state
  responded to both 308 and 309 estimates.
• Preliminary data distributed to Air Directors on
  September 2002.
• Follow-up questions completed November 2002.
• Final Draft completed January 2003.

7
SURVEY DESIGN

• Survey estimated resources needed beyond
  assistance from EPA / WRAP.
• Survey generic to both Section 308 309 tasks.
• Five phases of SIP Development
• Project Planning Development Adoption
  Approval and Implementation (no comparisons)

8
SURVEY DESIGN

• Assume SIP development process mostly generic
  between states.
• Resource units staff-weeks 40-person hours
  completed in one week or several.
• Average estimates provide a reasonable estimate
  of resources for a typical state.

9
SURVEY DESIGN

• States were classified as either Group A or
  Group B based upon complexity
• Number of BART sources
• Emission inventory complexity
• Number of mandatory Class I areas
• GROUP A GROUP B
• WA CA NM9 CO ID SD ND HI
• OR MT AZ NM8 AK UT NV WY

10
SURVEY RESULTS

• SIP Develop Phase most resource intensive.
• Project Planning / Adoption / Approval Phases
• have similar workloads between 308 and 309.
• Could not differentiate work load between 308 /
• 309 approach due to insufficient responses.
• States assumed significant help from WRAP.

11
VARIABILITY

• No state experience with RH plans.
• BART complexity and required workload.
• Complexity variation between states.
• Rules / programs required remain unknown.
• Workload predicted to update model inputs.
• Survey represents state best guesses.

12
CONCLUSIONS

• Additional State resources are needed.
• Continued funding for WRAP is needed.
• Model rules would be beneficial to states.

13
DISCUSSION POINTS

• Use of survey as a solicitation for additional
  EPA funding.
• Survey results distribution process.
• Air Director approval.
• END OF SLIDES