In 1999, the U.S. Environmental Protection Agency (EPA) announced a major effort to improve air quality in national parks and wilderness areas. The Regional Haze Rule calls for state and federal agencies to work together to improve visibility in 156 national parks and wilderness areas such as the Grand Canyon, Yosemite, the Great Smoky Mountains and Shenandoah. See below to learn about the work Florida DEP is doing for the current implementation period and other background information.
Current Implementation Period (2018 – 2028)
On Jan. 10, 2017, EPA published in the Federal Register a final rule revising the Regional Haze Rule. The revised Regional Haze Rule addresses the requirements for the second implementation period (2018 – 2028). States must evaluate and determine whether any cost-effective emission reduction measures and strategies are available to ensure reasonable progress toward natural visibility conditions in Class I areas during this implementation period. Florida Class I areas subject to the Regional Haze Rule are Chassahowitzka National Wildlife Refuge, Everglades National Park, and St. Marks National Wildlife Refuge.
Regional haze State Implementation Plans (SIPs) for the second implementation period are due July 31, 2021. EPA has distributed final guidance on the second implementation period that DEP is following throughout the SIP development process.
In February 2018, SESARM and the VISTAS states selected Eastern Research Group (ERG) and Alpine Geophysics to provide technical support to the regional haze project. ERG has completed 2011 base year photochemical modeling and modeled 2028 visibility impairment in Class I areas based on a 2028 projected emissions inventory.
Data from the Interagency Monitoring of Protected Visual Environments (IMPROVE) monitoring network show that sulfates continue to have a significant contribution to visibility impairment at all Florida Class I areas (see figure below). Point sources typically have the most significant contribution to visibility impairment at Class I areas due to emissions of sulfur dioxide (SO2) and nitrogen oxides (NOX), which are precursors to sulfates and nitrates. Therefore, VISTAS states focused on the Point source category to identify sources that would need to undergo a reasonable progress four-factor analysis.
To identify reasonable progress sources, the VISTAS states first screened sources using an Area of Influence (AOI) analysis. The AOI analysis evaluates a source’s 2028 projected actual emissions, distance to Class I area, and wind trajectories to estimate the source’s relative contribution to visibility impairment at each Class I area.
DEP further analyzed sources with at least 5% relative contribution to sulfate or nitrate visibility impairment through source apportionment modeling conducted by ERG. Source apportionment modeling tracks a source’s emissions and directly calculates how much visibility impairment in a Class I area is attributable to that source. The VISTAS states identified the threshold of 1.00% relative contribution to sulfate or nitrate visibility impairment as selecting an appropriate set of sources that are projected to have the highest impact on visibility impairment in Class I areas in 2028.
Florida has sent letters to 11 selected sources requesting that the facility either complete a four-factor analysis for each significant SO2 unit or demonstrate that the unit is effectively-controlled per EPA’s regional haze guidance and does not require four-factor analysis. Florida will review these analyses and issue permits for any controls that are identified for reasonable progress. Any resulting permits will be submitted as part of Florida’s regional haze SIP for the second implementation period, making them permanent and federally enforceable.
Florida continues to consult with the VISTAS states, EPA, and the Federal Land Managers throughout the SIP development process.
First Implementation Period (2008 – 2018)
The first regional haze SIP was due in 2007. The first implementation period required analysis of both Best Available Retrofit Technology (BART) sources and Reasonable Progress sources. BART determinations were only required for the first implementation period.
BART determinations evaluated SO2, NOX and PM10, and considered five factors: (1) the costs of compliance, (2) the energy and non-air quality environmental impacts of compliance, (3) any existing pollution control technology in use at the source, (4) the remaining useful life of the source, and (5) the degree of improvement in visibility which may reasonably be anticipated to result from the use of such technology. There were 46 BART-eligible sources in Florida.
Reasonable progress determinations evaluated only SO2 and were required to consider the four statutory factors in CAA section 169(A)(g)(1): (1) the costs of compliance, (2) the time necessary for compliance, (3) the energy and non-air quality environmental impacts of compliance, and (4) the remaining useful life of any potentially affected sources. Reasonable progress units in Florida were those with a Q/d metric greater than or equal to 50, where Q is the 2002 SO2 emissions of the unit and d is the distance from the unit to the nearest Class I area. There were 32 reasonable progress units at 15 facilities.
On Jan. 31, 2007, Florida adopted Rule 62-296.340, F.A.C., to address BART analyses and on Feb. 7, 2008, Florida adopted Rule 62-296.341, F.A.C., to address reasonable progress four-factor analyses. On March 19, 2010, Florida submitted the initial regional haze SIP which relied on these rules to represent commitment to achieve any required reductions by 2018, the end of the first implementation period. On Aug. 31, 2010, Florida amended the regional haze SIP to remove Rule 62-296.341, F.A.C., and propose to rely on EPA’s CAIR and Boiler MACT to satisfy reasonable progress. This SIP amendment also included case-by-case BART determinations for 5 facilities. Due to the remand of CAIR, Florida amended the SIP again on Sept. 17, 2012, to replace reliance on CAIR and Boiler MACT with case-by-case BART and reasonable progress determinations for all affected sources. Florida amended the SIP one last time on March 10, 2015 to include an additional BART limit for one source. The BART and reasonable progress determinations in the final regional haze SIP are summarized below.
Of the 46 BART-eligible sources:
25 were exempt due to meeting modeling exemption criteria, with 8 receiving permits to meet the criteria.
9 were exempt due to shutting down.
2 demonstrated top-level controls.
10 completed a full BART analysis, with 8 facilities receiving permits to install new controls, upgrade existing controls or set limits.
Of the 32 reasonable progress units:
8 units at 5 facilities required a full four-factor analysis with 2 facilities receiving permits.
3 units at 3 facilities took permit limits to reduce their Q/d to less than 50 and did not require four-factor analysis.
11 units at 3 facilities were permitted to permanently shut down and did not require four-factor analysis.
The remaining 10 units were located at 6 BART sources which completed BART determinations in lieu of four-factor analysis.
On Aug. 29, 2013, EPA gave full approval of Florida’s regional haze SIP which was submitted on March 13, 2010, as amended on Aug. 31, 2010, and Sept. 17, 2012. On Oct. 23, 2015, EPA approved Florida’s March 10, 2015 revision to the regional haze SIP which included the additional BART limit for one source.
On March 10, 2015, Florida submitted a regional haze progress report SIP revision to EPA, addressing the requirement that states submit periodic reports describing progress to date on the regional haze plan and a determination of the adequacy of a state’s existing regional haze plan. This progress report SIP demonstrated that Florida was on track to meet the visibility improvement goals set in the regional haze SIP. EPA approved Florida’s regional haze progress report SIP on Aug. 2, 2016.
EPA’s regional haze program addresses requirements under the Clean Air Act (CAA) for the protection of visibility in national parks and wilderness areas designated as mandatory Class I federal areas. The following Class I areas in or near Florida are subject to the Regional Haze Rule:
Visibility in Class I areas can be affected by regional haze caused by the cumulative effects of numerous sources located over a wide geographic area.
The regional haze program aims to improve visibility on the 20% most impaired days (previously the 20% haziest days) and ensure visibility does not degrade on the 20% best days in Class I areas. Progress in visibility improvement is compared to each Class I area’s “uniform rate of progress” or URP which extends from visibility conditions in the baseline period of 2000-2004 to natural visibility conditions in 2064. The figure below shows the current monitored visibility in each Florida Class I area, and the projected visibility in 2028 from EPA’s Regional Haze Modeling. Visibility conditions are currently well below the URP and are projected to remain below the URP with on-the-books controls.
EPA’s Regional Haze Rule initially promulgated July 1, 1999, requires states to submit a series of SIPs to ensure reasonable progress towards natural visibility conditions in Class I areas. As part of the SIP development process, states must evaluate and determine whether any cost-effective emission reduction measures and strategies are available to ensure reasonable progress in the current implementation period.
SESARM (Southeastern States Air Resource Managers, Inc.) coordinates regional haze planning for ten Southeastern states, including Florida, through the regional planning organization VISTAS (Visibility Improvement State and Tribal Association of the Southeast). VISTAS is responsible for convening state, local and tribal air pollution control agencies in the southeast and collaborating on regional air quality analysis work necessary to support development of regional haze SIPs.
The Florida Department of Environmental Protection is the state’s lead agency for environmental management and stewardship – protecting our air, water and land. The vision of the Florida Department of Environmental Protection is to create strong community partnerships, safeguard Florida’s natural resources and enhance its ecosystems.