AQ_GEN_PLNG_20220404_SIP_RH-SIP_AppF2b

Appendix F-2b

VISTAS Consultation with IN Office of Air Quality

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Correspondence Record
Date From To Description
June 22,
2020
VISTAS IN Office of
Air Quality
Request for Regional Haze Reasonable
Progress Analysis for Indiana Sources
Impacting VISTAS Class I Area
February
12, 2021
IN Office of
Air Quality
VISTAS Email correspondence between IN Office of Air
Quality and VISTAS

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Visibility Improvement State and Tribal Association of the Southeast

June 22, 2020

Keith Baugues, Assistant Commissioner
Indiana Office of Air Quality
100 North Senate Avenue, IGCN 1003
Indianapolis, Indiana 46204

RE: Request for Regional Haze Reasonable
Progress Analyses for Indiana Sources
Impacting VISTAS Class I Areas

Dear Mr. Baugues:

The Regional Haze Regulation 40 CFR § 51.308(d) requires each state to “address regional haze
in each mandatory Class I Federal area located within the State and in each mandatory Class I
Federal area located outside the State which may be affected by emissions from within the
State.” 40 CFR § 51.308(f) requires states to submit a regional haze implementation plan
revision by July 31, 2021. As part of the plan revision, states must establish a reasonable
progress goal that provides for reasonable progress towards achieving natural visibility
conditions for each mandatory Class I Federal area (Class I area) within their state . 40 CFR §
51.308(d)(1) requires that reasonable progress goals “must provide for an improvement in
visibility for the most impaired days over the period of the implementation plan and ensure no
degradation in visibility for the least impaired days over the same period.”

In establishing reasonable progress goals, states must consider the four factors specified in §
169A of the Federal Clean Air Act and in 40 CFR § 51.308(f)(2)(i). The four factors are: 1) the
cost 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. Consideration of these four factors is frequently referenced as the “four-
factor analysis.”

To assist its member states, the Visibility Improvement State and Tribal Association of the
Southeast1 (VISTAS) and its contractors conducted technical analyses to help states identify

1 The VISTAS states are Alabama, Florida, Georgia, Kentucky, Mississippi, North Carolina, South Carolina,
Tennessee, Virginia, and West Virginia.

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sources that significantly impact visibility impairment for Class I areas within and outside of the
VISTAS region. VISTAS initially used an Area of Influence (AoI) analysis to identify the areas and
sources most likely contributing to poor visibility in Class I areas. This AoI analysis involved
running the HYSPLIT Trajectory Model to determine the origin of the air parcels affecting
visibility within each Class I area. This information was then spatially combined with emissions
data to determine the pollutants, sectors, and individual sources that are most likely
contributing to the visibility impairment at each Class I area. This information indicated that the
pollutants and sector with the largest impact on visibility impairment were sulfur dioxide (SO2)
and nitrogen oxides (NOx) from point sources. Next, VISTAS states used the results of the AoI
analysis to identify sources to “tag” for PM (Particulate Matter) Source Apportionment
Technology (PSAT) modeling. PSAT modeling uses “reactive tracers” to apportion particulate
matter among different sources, source categories, and regions. PSAT was implemented with
the Comprehensive Air Quality Model with extensions photochemical model (CAMx Model) to
determine visibility impairment due to individual sources. PSAT results showed that in 2028 the
majority of visibility impairment at VISTAS Class I areas w ill continue to be from point source
SO2 and NOx emissions. Using the PSAT data, VISTAS states identified, for reasonable progress
analysis, sources shown to have a sulfate or nitrate impact on one or more Class I areas greater
than or equal to 1.00 percent of the total sulfate plus nitrate point source visibility impairment
on the 20 percent most impaired days for each Class I area. This analysis has identified the
following sources in Indiana that meet this criterion:

• Indianapolis Power & Light Petersburg (18125-7362411)
• Gibson (18051-7363111)
• Indiana Michigan Power DBA AEP Rockport (18147-8017211)

Information regarding projected 2028 SO2 and NOx emissions and visibility impacts on VISTAS
Class I areas is shown in the tables attached to this letter (Attachment 1).

As required in 40 CFR § 51.308(d)(1)(i)(A), VISTAS, on behalf of Alabama, Georgia, Kentucky,
North Carolina, Tennessee, and West Virginia, requests that Indiana conduct, or require that
the sources in question initiate, and share when completed, the results of a reasonable
progress analysis for each noted source with VISTAS. This will be helpful to the VISTAS states as
they begin the formal Federal Land Manager consultation process for their individual draft
Regional Haze Plans in early 2021. So that the VISTAS states can include the results of your
state's reasonable progress analyses in developing the long-term strategies for Class I areas in
their states, we request that you submit this information to VISTAS no later than October 30,
2020. If any reasonable progress analyses cannot be completed by this date, please provide, no
later than this date, notice of an attainable date for completion of the analysis. If you
determine that a four-factor analysis is not warranted for one or more of the identified sources,
please provide the rationale for this determination by the reques ted date.

In developing projected 2028 emissions for these sources, VISTAS utilized ERTAC_16.1
emissions projections with additional input from LADCO. Please review these projections to

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verify that they are reasonable. Should you be aware of significantly different emission
projections for 2028 for any of the sources or pollutants, please provide revised estimates
within thirty (30) days of the date of this letter. The applicable VISTAS states will review any
revised emission estimates, determine if reasonable progress analyses are not needed to meet
their regional haze obligations, and notify you accordingly.

Updated 2028 emission projections, if necessary, the results of your state’s reasonable progress
analyses for the requested sources, and any necessary ongoing communications should be sent
via email to [e-mail].

Should you have any questions concerning this request, please contact me through September
30, 2020, at 404-361-4000 or [e-mail].

Sincerely,

John E. Hornback
Executive Director
Metro 4/SESARM/VISTAS

Attachment

Copies: Ron Gore, Alabama Air Division
Karen Hays, Georgia Air Protection Branch
Melissa Duff, Kentucky Division for Air Quality
Mike Abraczinskas, North Carolina Division of Air Quality
Michelle Walker Owenby, Tennessee Division of Air Pollution Control
Laura Crowder, West Virginia Division of Air Quality
Zac Adelman, Lake Michigan Air Directors Consortium

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Attachment 1: Projected 2028 SO2 and NOx Emissions and VISTAS Class I Area Impacts

Table 1. Indianapolis Power & Light Petersburg (18125-7362411)
Modeled SO2 = 9,422.1 tpy, Modeled NOx = 5,355.6 tpy

Table 2. Gibson (18051-7363111)
Modeled SO2 = 12,999.6 tpy, Modeled NOx = 8,620.0 tpy

Table 3. Indiana Michigan Power DBA AEP Rockport (18147-8017211)
Modeled SO2 = 10,779.0 tpy, Modeled NOx = 8,475.1 tpy

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Sipsey Wilderness Area 0.258 0.026 16.370 1.57% 0.16%
Mammoth Cave National Park 0.264 0.068 25.289 1.04% 0.27%

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Sipsey Wilderness Area 0.270 0.029 16.370 1.65% 0.18%
Mammoth Cave National Park 0.411 0.084 25.289 1.63% 0.33%
Shining Rock Wilderness Area 0.151 0.008 12.313 1.23% 0.07%
Linville Gorge Wilderness Area 0.138 0.008 12.884 1.07% 0.07%
Great Smoky Mountains NP 0.146 0.037 13.916 1.05% 0.27%
Cohutta Wilderness Area 0.137 0.002 13.229 1.03% 0.02%
Joyce Kilmer-Slickrock Wilderness 0.139 0.029 13.694 1.02% 0.21%
Otter Creek Wilderness 0.193 0.009 19.077 1.01% 0.05%

Impacted VISTAS Class I Areas
Sulfate
PSAT
(Mm-1)
Nitrate
PSAT
(Mm-1)
Total EGU & non-
EGU Sulfate +
Nitrate (Mm-1)
Sulfate
PSAT %
Impact
Nitrate
PSAT %
Impact
Sipsey Wilderness Area 0.327 0.050 16.370 1.99% 0.31%
Mammoth Cave National Park 0.426 0.085 25.289 1.68% 0.33%
Cohutta Wilderness Area 0.181 0.005 13.229 1.37% 0.04%
Shining Rock Wilderness Area 0.156 0.012 12.313 1.27% 0.09%
Great Smoky Mountains NP 0.166 0.035 13.916 1.19% 0.25%
Joyce Kilmer-Slickrock Wilderness 0.154 0.030 13.694 1.12% 0.22%
Linville Gorge Wilderness Area 0.142 0.012 12.884 1.10% 0.09%
Otter Creek Wilderness 0.191 0.007 19.077 1.00% 0.04%
From:Chad LaFontaine
To:McLeod, Doris (DEQ); Strait, Randy P; James Johnston; Boylan, James
Subject:[External] FW: VISTAS Interstate Consultation Letters
Date:Thursday, February 25, 2021 3:12:14 PM
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to Report Spam.
See the Indiana responses below.

From: DELONEY, SCOTT <[e-mail]>
Sent: Friday, February 12, 2021 2:30 PM
To: Chad LaFontaine <[e-mail]>
Cc: STUCKEY, MATT <[e-mail]>
Subject: Re: VISTAS Interstate Consultation Letters

Hi Chad. LADCO is had to rerun the model and we do not expect to have final results for a few
more weeks. We have been working on a detailed response to your request, but having the
final results in hand is important for us to properly characterize the impacts of the EGUs
identified. We really appreciate your patience on this matter. Right now it looks like early
March for a detailed response.

From: Chad LaFontaine <[e-mail]>
Sent: Friday, February 12, 2021 3:23 PM
To: DELONEY, SCOTT <[e-mail]>
Cc: STUCKEY, MATT <[e-mail]>
Subject: RE: VISTAS Interstate Consultation Letters

**** This is an EXTERNAL email. Exercise caution. DO NOT open attachments or
click links from unknown senders or unexpected email. ****
I hope you all are well. I’m following up on the email below at the request of the VISTAS states.
Some of the states have gotten far along in their SIP development and are being asked by EPA about
their consultation information and whether they have followed up appropriately. Please provide any
update on the information you indicated below. Let me know if you need additional information
from me.

Thank you,

Chad LaFontaine, P.E.
Executive Director
Metro 4/SESARM
1252 W Government St. Unit 1375
Brandon, MS 39043
(cel) 601-624-6015
[e-mail]

From: DELONEY, SCOTT <[e-mail]>
Sent: Thursday, October 22, 2020 12:45 PM
To: Chad LaFontaine <[e-mail]>
Cc: Baugues, Keith <[e-mail]>; STUCKEY, MATT <[e-mail]>
Subject: Re: VISTAS Interstate Consultation Letters

Mr. LaFontaine, I am responding on behalf of Assistant Commissioner Keith Baugues and Deputy
Assistant Commissioner Matt Stuckey to provide an update on where Indiana is with regard to
your request. We are working closely with LADCO to identify and complete a detailed analysis of
sources within the region that contribute to Class 1 areas throughout the country, including those
within the VISTAS region. This work includes modeling, source and sector tagging, and 4-factor
analyses for affected sources.

Unfortunately, we are not going to have our technical work complete within a timeframe that
allows us to adequately respond to your request by 10/30/2020. However, we do expect to have
everything complete and quality assured well ahead of the Regional Haze SIP deadline. We will
be responding to your request via formal letter with technical support documentation in early
2021.

Please be advised that Keith is retiring, effective 10/30/2020. Matt will be the primary contact for
Indiana in the interim. If you would like additional information or clarification concerning this
matter, feel free to contact me or Matt. Thank you.

COVID-19 Resources:
· Indiana State Dept. of Health (ISDH) COVID-19 Call Center: Call 877-826-0011
(available 8:00 am- 5:00pm daily).
· Anthem NurseLine: Call 800-337-4770 or visit the Anthem NurseLine online for a
FREE symptom screening. Available to anyone with an Anthem health plan (this includes
State of IN employees)
· Anthem Employee Assistance Program (EAP): Available to full-time state employees
and their household members regardless of health plan participation. Call 800-223-7723 or
visit anthemeap.com (enter State of Indiana) for crisis counseling, help finding child/elder
care, legal/financial consultation and much more.

Scott Deloney, Chief
Air Programs Branch
IDEM-OAQ

From: Chad LaFontaine <[e-mail]>
Sent: Thursday, October 15, 2020 3:17 PM
To: [e-mail] <[e-mail]>; Bybee, Darcy
<[e-mail]>; Baugues, Keith <[e-mail]>; STUCKEY, MATT
<[e-mail]>; [e-mail] <[e-mail]>;
[e-mail] <[e-mail]>
Subject: VISTAS Interstate Consultation Letters

**** This is an EXTERNAL email. Exercise caution. DO NOT open attachments or
click links from unknown senders or unexpected email. ****
Directors,

I hope you all are well. On June 22, 2020, the former Executive Director of Metro 4/SESARM sent
you a letter on behalf of the VISTAS states asking that one or more major point sources in your state
undergo a reasonable progress analysis and a four-factor analysis if warranted. I’ve been asked to
provide you with a reminder of the information request date of October 30, and to provide you with
updated contact information for any deliverable. If you have any questions or need to discuss
further, please let me know.

I am the new Metro 4/SESARM Executive Director replacing John Hornback. I have worked with
many of you as the former Air Director for Mississippi. Please direct responses to me at the contact
information below. I look forward to receiving your information and thank you for your efforts.

Chad LaFontaine, P.E.
Executive Director
Metro 4/SESARM
1252 W Government St. Unit 1375
Brandon, MS 39043
(cel) 601-624-6015
[e-mail]