SIP Revision: Regional Haze
Regional Haze State Implementation Plan (SIP)
At the February 25, 2009 agenda, the commission adopted revisions to the Texas SIP for visibility protection at Federal Class I areas. There was no rulemaking adopted with this SIP. The revision was project No. 2007-016-SIP-NR.
- SIP Narrative
- Response to Comments
- SIP Narrative comparison of changes from proposal to adoption
- Executive Summary
The Regional Haze SIP revision is the plan Texas must submit to the United States Environmental Protection Agency (EPA) to show how Texas will reduce regional haze to natural conditions. This SIP revision includes all existing control strategies for the Dallas and Houston areas, other statewide and federal controls, and Best Available Retrofit Technology (BART).
The long-term goal is to restore air quality to natural conditions. Natural conditions are defined by the EPA as the visibility conditions that would be experienced in the absence of pollution from human activities. The goal set by Congress is for all Federal Class I areas to meet natural conditions by 2064. The “glide path” is the path to the 2064 goal. Currently, the baseline haze level at Big Bend and Guadalupe Mountains National Parks is approximately 16 deciviews.
Solid red line represents glide slope.
Source: Adapted from EPA-454/B-03-005, Guidance for Estimating Natural Visibility Conditions Under the Regional Haze Program.
The BART Rule was adopted by the TCEQ in January 2007 to allow the state to require BART modeling from specific industries or sources. A number of sources that appeared to be BART-eligible applied for and obtained legally enforceable reductions in their allowable emissions. Some of the reductions were from shut downs; others resulted from reducing permitted emissions rates on units that had larger allowables than they needed to operate. After final modeling incorporated these reductions in allowable emissions, Texas was left with no BART-eligible sources. An updated list of potentially BART-eligible sources is in the SIP Appendix 9-13. For more information on BART, see the related web page Regional Haze: Rulemaking (BART and CAIR).
Texas used the Central Regional Air Planning Association's (CENRAP) template for the Regional Haze SIP revision. The CENRAP states worked together with the EPA and Federal Land Managers to develop a format that stakeholders found acceptable. Each state may adapt the template as needed.
Regional Haze Consultation with other States
The TCEQ provided a summary paper to participants in the regional haze consultation calls on July 11, 18 and 31, 2007. The TCEQ held these calls with other states, Federal Land Managers, and the EPA and offered the opportunity for other interested parties to listen to the consultation calls.
Texas' Regional Haze Summary of Major Issues is the summary the TCEQ provided to the participants in the consultation conference calls. The summaries of the three consultation conference calls are provided below:
The TCEQ will continue to consult with other states in the future. Regional Haze SIP revisions are required every 10 years, so the next revision is due to EPA in 2018. Every five years, the TCEQ is required to assess the state's progress towards natural conditions and may do a revision if needed in 2014.
The TCEQ developed four issue papers regarding its analyses of some of the technical issues in developing the Regional Haze SIP revision. These issue papers were provided to the participants in the consultation calls.
- Uniform Rates of Progress and Projected 2018 Reasonable Progress Goals The first issue concerns the uniform rate of progress to reduce haze by 2018. The TCEQ’s preliminary analyses indicate that, without international emissions, Texas’ Class I areas would be close to achieving the uniform rate of progress for 2018.
- Dust Storms and Regional Haze The second issue concerns natural events that contribute to regional haze. Dust storms, which originate in natural desert areas, are recurring natural air pollution episodes that are not controllable. Further, such dust storms contribute to some of the highest regional haze and particulate matter (PM) events measured in West Texas. West Texas is one of the areas of the continental United States with a high frequency of dust storms due to the combination of eroded soils and high wind speeds in the Chihuahuan Desert. Texas cannot control these natural events, and consequently these events are considered part of the natural conditions in developing a Regional Haze SIP.
- Estimating Natural Conditions Based on Revised IMPROVE Algorithm The third issue concerns natural conditions or conditions that would be present without pollution from human activities. Natural conditions are calculated using the IMPROVE algorithm or equation, which estimates visibility from particulate matter measurements. The IMPROVE program, Interagency Monitoring of Protected Visual Environments, is a cooperative effort governed by a Steering Committee composed of representatives from Federal and state organizations. The IMPROVE program was established for visibility-related research, including the advancement of monitoring instrumentation, analysis techniques, visibility modeling, policy, and field studies. The IMPROVE algorithm was revised in 2005. The Regional Haze SIP revision uses the revised IMPROVE equation for all baseline, control strategy, and natural condition calculations. For all aerosol components, except coarse mass and fine dust, the inputs to the natural condition estimates are the default Natural Conditions II committee estimates for Big Bend and Guadalupe Mountains National Parks. Because of the dominant contribution that dust storms and blowing dust make to coarse mass and fine soil at these parks, the average measured concentrations during the baseline period are the inputs for these two species.
- Integrated Planning Model Projections of Electric Generating Unit Emissions for the Regional Haze SIP Revision The fourth issue concerns the use of the EPA’s Integrated Planning Model (IPM), Version 2.19, versus Version 3.0. Based on its analyses, the TCEQ concluded that photochemical modeling using inputs for electric generating units (EGU) from the earlier version of the IPM was a viable option for SIP planning in Texas. The conclusion was based on two primary findings: (1) total Texas EGU emissions of SO2 predicted by both IPM versions were similar for the planning year 2018; and (2) potential impacts of EGUs on Class I areas, based on upwind groupings of EGU-emitted SO2, were the same or nearly the same for both IPM versions.
As required by the Regional Haze Rule 40 CFR 51.308, the TCEQ made the Federal Land Managers' comments available before the public hearing. The following comments were received:
The following comments are in no particular order.
- U.S. Environmental Protection Agency Comments
- CLEAN Houston Comments
- Sierra Club, Lone Star Chapter Comments
- approximately 300 individuals commented via fax
Key dates in proposed SIP revision schedule:
- TCEQ adoption date: February 25, 2009
- EPA evaluation: by November 15, 2013
- Next regional haze review: scheduled for March 2014
- Review every five years: through 2064 or until attainment
Due to an amended court order in 2012, the EPA is expected to take final action on Texas' 2009 Regional Haze SIP by November 15, 2013.