Note: These questions and answers pertain to the 2022 Regional Haze State Implementation Plan (SIP)/Regulations Proposed Revisions. The information was current at the time of posting, but may be outdated after the adoption of regulations and plan.

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What is Regional Haze?

Regional Haze is defined as visibility impairment caused by the emission of air pollutants from numerous sources over a wide geographic area. Congress passed the Regional Haze Rule in 1999 which is intended to improve visibility in certain national parks, forests, and wilderness areas that met specific criteria under the Clean Air Act. These areas are classified as “Class I” areas. The Environmental Protection Agency (EPA) regulations require states to analyze pollution impacts on their Class I areas and develop a State Implementation Plan (SIP) to improve visibility by 2064. In Alaska, the following National Parks and Wilderness Areas fall under the jurisdiction of this program:

• Denali National Park
• Tuxedni National Wilderness Area
• Simeonof National Wilderness Area
• Bering Sea Wilderness Area

How does Regional Haze impact my community?

To date, individual communities in Alaska have not been the primary focus of the Regional Haze Rule planning. While all sources of air pollution that could impact Alaska’s Class I areas are assessed, much of the federal rule focuses on individual sources of pollution or groups of sources. In this plan, a focus is placed on assessing pollution from major stationary sources, such as power plants and other industrial facilities, along with land clearing burns over 40 acres that can generate smoke plumes that may impact the Class I area. Other types of sources are grouped into what are called sectors, such as aircraft and marine emissions, which are looked at as an aggregate within the plan. No specific additional controls are being proposed for community-based air pollution sources, like motor vehicles, small equipment, or space heating, in this plan. Existing state and federal air quality regulations put in place to protect public health remain in effect throughout the state, which also help to reduce pollution that can impact visibility.

Is the state proposing any major changes to regulations in this plan?

There are two main changes proposed in the state’s air quality regulations. The first would establish a new Regional Haze Visibility Protection Area to identify the area of the state where air pollution emissions have the most potential to impact the Class I areas; the methodology used to develop the area is available for review and is included in an appendix to the plan. The second change proposes an increase in reporting requirements for new and existing industrial sources located in the Regional Haze Visibility Protection Area, including additional information that will be required during the permit application process. Alaska is a very large state geographically, so these new requirements would assist in focusing efforts and resources on pollution sources more likely to contribute to visibility impairment in Alaska’s Class I areas.

Will any regulations directly impact my home?

It is highly unlikely the proposed changes in this plan and the associated regulations will directly impact your home. If you conduct large, prescribed burns over 40 acres on your personal property, there is potential for impacts to your burning operations. DEC already has requirements for permitting burns of this size, so if you perform burns on this scale, please reach out to DEC directly to request more information on the existing program requirements.

Will any regulations directly impact my business?

Industrial facilities that are located within the proposed Regional Haze Visibility Protection Area may have additional reporting requirements. New potential facilities or modifications to existing facilities may require additional information in the permit application process to ensure that any new emissions do not adversely impact the Regional Haze Plan’s progress goals.

What are some of the elements in this plan?

The new Regional Haze Plan contains updated technical information and analysis about air pollution sources, air monitoring trends in visibility at the Class I Areas, and updates the state’s long term strategy for addressing visibility impairment. Some of the updated elements within the update plan include:

• The plan includes a visibility progress report for each of the state’s Class I Areas. This progress report charts improvements since the last state Regional Haze update was completed in 2015.
• The plan and associated regulations propose a new Regional Haze Visibility Protection Area to better identify the areas within Alaska where air pollution emissions have the most potential to impact the Class I areas; the methodology used to develop the area is available for review and is included in an appendix to the plan.
• The plan and associated regulations propose some additional data reporting for existing industrial sources within the Regional Haze Visibility Protection Area and some additional analysis during the air permitting process for new and modified industrial sources.
• The plan includes an updated Enhanced Smoke Management Plan (ESMP) developed in coordination with the Alaska Wildland Fire Coordinating Group (AWFCG). Smoke from large scale burning has the potential to impact visibility in Alaska’s Class I areas. Changes to this plan include greater data sharing between DEC and land management agencies to assist with calculating emissions from wildfires and prescribed burns. The Alaska Department of Natural Resources (DNR) will work with DEC to ensure increased cooperation on data sharing from its new prescribed fire registry system.
• The plan includes an update on the status of each of the major sources that were analyzed and included in the First Regional Haze Plan in order to meet the federal requirements for Best Available Retrofit Technology (BART). The BART program focused on facilities built between 1962 and 1977. Facilities built during this time period in Alaska included the Nikiski Oil Refinery, the George Sullivan Power Plant in Anchorage, and the Healy Power Plant near Denali National Park. These facilities were required to undergo review and control during the development of Alaska’s first Regional Haze Plan.
• The plan identified three major industrial sources, Eielson Air Force Base and Golden Valley Electric Association’s (GVEA’s) North Pole and Healy Power Plants where proposed additional requirements appear to be warranted to support visibility improvements at the Class I areas. Eielson Air Force Base Power Plant and the GVEA Healy Power Plant would require additional analyses of pollution control equipment if existing older emissions units planned for retirement are not retired within certain timeframes. The GVEA North Pole Power Plant would be required to use Diesel #1 fuel during the warm season to reduce sulfur emissions, while the facility is already required to switch to ultra-low sulfur diesel during winters as part of the Fairbanks fine particulate matter (PM₅) State Implementation Plan.
• The plan contains a new long-term strategy, including updated emissions and modeling, and analyses of mobile and stationary sources, which state planners will utilize through the end of the planning period in 2028.

• For more detailed information on the plan elements, please reference the individual Sections and Appendices of III.K.13 on the Regional Haze Public Notice Draft webpage.

Has pollution increased at any of Alaska's Class I Areas?

The Regional Haze Plan identifies the trends in air pollution at air monitoring sites in and near Alaska’s Class I areas. These monitoring trends vary by site and pollutant from year to year. Information on the air monitoring network (known as the IMPROVE network) and trends can be found in Sections III.K.13.C and III.K.13.D of the Plan on the Regional Haze Public Notice Draft webpage.

What are the overall goals of the Regional Haze Plan?

The state must show continued improvement at all Class I Areas until natural visibility conditions are met in each area. Natural conditions have been defined by the Environmental Protection Agency (EPA) using DEC-generated emissions data and visibility data from the IMPROVE visibility monitors located near the Class I Areas. This data allows the state to calculate a uniform rate of progress over time for use in the plan; this can be displayed graphically and helps the state to assess the progress being made toward natural conditions by 2064. DEC tracks emissions and monitoring data over time to measure progress toward the long-term goal. DEC is not required to report yearly to EPA; instead, reporting is done in 5-year intervals. Every 10-years the state is required to submit a full plan update with progress reports between each full update.

How often does the state review progress and update the Regional Haze Plan?

Every 10 years, the state is required to submit a new plan that demonstrates continued progress toward achieving natural visibility conditions by the Clean Air Act’s 2064 goal. The state must also submit an interim progress report 5 years after submitting a full plan to show it is on track in meeting the identified progress goals for the current ten-year planning period. 

What happens if the state does not show yearly improvements?

If visibility does not improve, or pollution increases from controllable sources, the state may be required to add additional controls on sources that impact the Class I area to reduce emissions and improve visibility.

What happens if the state does not submit a Regional Haze Plan that meets federal requirements?

If the state does not submit a Regional Haze Plan to the Environmental Protection Agency (EPA), the EPA would be required to develop and implement a Federal Implementation Plan (FIP). This would mean that EPA would identify and implement any controls on Alaskan air pollution sources that are needed to meet Regional Haze Rule requirements.

What outreach is available to understand this plan?

There are informational materials and two presentations posted online on the Regional Haze Public Notice Draft webpage to assist you in understanding the proposed plan. If you have additional questions, they may be submitted in writing by May 11, 2022, as detailed below under Additional Information. All written questions will be answered and posted on this Question and Answer page prior to the end of the public comment period.

What are the next steps for this plan after the public comment period ends?

After the public comment, DEC will review all comments and prepare a document that provides responses to comments. The plan and regulations could be modified in response to comments received. The response to comments, and the edited plan and regulations will be presented to the Commissioner for consideration and DEC adoption. If adopted, the plan and regulations will then go to the Department of Law (DOL) for their legal review. After DOL review, the plan and regulations will go to the Lieutenant Governor for final signature and filing. Upon the Lieutenant Governor’s signature, an effective date will be issued for thirty days after signing. DEC will implement the plan and submit it to the Environmental Protection Agency (EPA) per federal requirements. Once EPA receives the state’s plan, EPA staff will review it to ensure it meets federal requirements and then take action(s) based on their review. EPA’s actions related to approving the state plan are also subject to public review and comment.

Why is the reported SO₂ emission rate for Healy unit 1 so much higher in 2016 than in 2017-2019?  The reported SO₂ emission rate (based on CEMS data) is 105.2 lb/hr in 2016 versus 77.1 lb/hr, 84.9 lb/hr and 75.5 lb/hr in 2017, 2018 and 2019, respectively.  Based on information reported in Table III.K.13.F-21 (Healy Power Plant SO₂ Emissions) of the draft SIP, SO₂ emissions were also much higher in 2014 and 2015.

The drop in the reported SO₂ emission rate for Healy Unit 1 that occurred in 2017 resulted from a federally enforceable permit condition, that limits SO₂ emissions from the coal fired boilers to no more than 0.30 lb/MMBtu. The limit went into effect February 4, 2017.

Minor Permit AQ0173MSS01 was issued on April 14, 2014, to include the requirements of the Consent Decree Civil Action No. 4:12-cv-00025-RRB (Consent Decree) dated November 19, 2012, between Golden Valley Electric Association (GVEA) and the United States of America on behalf of the US EPA. Section 1.2 (The Reason to Require a Minor Permit) from the Technical Analysis Report (TAR) for AQ0173MSS01 references the Consent Decree and states:

Phase 3 - Improve the Dry Sorbent Injection system currently on EU 1 no later than September 30, 2015, or 18 months after EU 2 first fires coal after November 19, 2012 whichever is later. This phase may be concurrent with Phase 1. After January 1, 2016, the combined SO₂ emissions from EUs 1 and 2 should not exceed 701 tpy. The 30-day rolling average SO₂ emission rate of EU 1 should not exceed 0.30 lb/MMBtu.

This requirement became Condition 45 of the current Operating Permit AQ0173TVP03, issued on December 24, 2018. Condition 45 states, “Effective February 4, 2017, the SO₂ emission rate from EU ID 1 shall not exceed 0.30 lb/MMBtu, 30-day rolling average.” This requirement to meet the SO₂ emissions limit of 0.30 lb/MMBtu in the beginning of 2017 appears to correspond with the drop in emissions discussed in the comment. However, the steps taken to improve the dry sorbent injection system to achieve this drop in reported SO₂ emissions are unknown by the Department.

Can DEC please provide the hourly SO₂ and NO_x CEMs data for Healy units 1 and 2 for 2015 through 2020?

Condition 20.2 of Operating Permit AQ0173TVP03 requires GVEA to operate a certified continuous emission monitoring system (CEMS) on each of EUs 1 and 2 to measure and record the SO₂, NOx, and O₂, or CO₂ emissions discharged to the atmosphere. This data is required to be kept on-site for at least five years after the date of collection, however, it is not required to be reported to the Department.

Therefore, the Department does not have the requested hourly SO₂ and NOx CEMs data for Healy Units 1 and 2 since it was not required to be submitted, and the Department has not has a need to request that information.

Can ADEC please provide the cost analysis spreadsheets for the 2009/2010 BART control costs for Healy unit 1 cited in the draft SIP?

The Department does not have copies of the cost spreadsheets used for the 2009/2010 BART control analyses for Healy Unit 1. The costs used in the BART determination referenced in the Regional Haze SIP were provided to the Department by Enviroplan Consulting in the Revised Final BART Determination Report for the GVEA Healy Power Plant dated June 1, 2010. This report is included in the Appendix III.K.6 Best Available Retrofit Technology (BART) Documentation PDF on DEC’s website, available at; https://dec.alaska.gov/air/anpms/regional-haze/sip/. The Department searched our internal BART records and were not able to locate the underlying spreadsheets used in this final report.

What is the current control efficiency of the existing DSI system on Healy unit 1?  The SIP documents imply that the current DSI system is achieving 50% control. (The full question is longer, and a link to it can be found in the answer section below.)

The complete question can be found at full text of the question 

The Department does not know what the uncontrolled SO₂ emission rate is for the boiler at Healy Unit 1. Also, it does not know what the actual control efficiency being achieved by the DSI system is. The Department did not intend to imply that the current DSI system is achieving 50% SO₂ emissions reduction, only that EPA’s Air Pollution Control Cost Manual estimates that a DSI system can achieve control efficiencies of 50-70%. GVEA’s operating permit does not require SO₂ testing prior to the boiler’s exhaust stream entering the DSI control system. Only after the exhaust stream has passed through the control system, is it tested to determine its SO₂ emission rate. Since there is no uncontrolled SO₂ emission rate data available, there is no way to calculate the control system’s SO₂ removal efficiency.

Regarding the type of coal being combusted at the Healy Power Plant. GVEA receives all of its coal from the Usibelli Coal Mine which reports a coal type of “Subbituminous C” in their Coal Data Sheet at: http://www.usibelli.com/coal/data-sheet

Who is responsible for conducting the four factor analysis for a stationary source (state or facility)?

Under the August 20, 2019, Regional Haze Guidance Document (40 CFR 51.308(d)) the State is responsible to develop a SIP that includes 4-factor analyses for certain stationary sources.  While the State must include these analyses to meet the planning requirements, it cannot accurately conduct 4-factor analyses for individual stationary sources without having detailed and specific information from the facility being analyzed.  As a result, the State typically requests that the data be gathered and an analysis be prepared by the owner/operator of the facility for use in the plan.  This same approach is used in the air permit process for Prevention of Significant Deterioration (PSD) permits when Best Available Control Technology (BACT) analyses are required.

Does a four factor analysis mean that a source will be required to apply emissions reduction techniques on a stationary source or source categories?hat is Regional Haze?

The outcome of a four factor analysis is case specific to the source or source category and requires an evaluation of feasible control options relative to four statutory factors:  1. Cost of implementing emission controls; 2. Time necessary to install such controls; 3. Energy and non-air quality impacts associated with installing controls; and 4. The remaining useful life of the facility.  It is possible that the outcome of the analysis is a determination that a source or source category is already effectively controlled and that no additional control is warranted.  It is also possible that control options are found to be feasible, resulting in additional emission reduction techniques being required for a source or source categories.

Could the state help us understand how the emission reductions are going to equate to visibility reductions? For example, how much visibility improvement are the models showing from 100 ton per year reduction of SO₂ emissions from Healy?

Modeling related information is available in the proposed Regional Haze State Implementation Plan, Section III.K.13.g., and the SIP also discusses how visibility impairing pollutants including sulfur dioxide impact visibility by absorbing and scattering light (see Section III.K.13.b.).  These air pollutants extinguish light and prevent it from reaching a viewer’s eye; this “light extinction” affects visibility. Haze is the reduction in visibility caused when sunlight encounters tiny particles in the air.  It is not possible for the Department to specifically answer this question with respect to visibility improvement at the Class I area from a 100 ton per year SO₂ emission reduction at the Healy power plant as that is not an analysis that was performed and included in the proposed SIP nor is it possible for the Department to perform such an analysis prior to the comment deadline.  Section III.K.13.g notes that Alaska does not have meteorological modeling or a photochemical grid modeling platform available to perform modeling to evaluate impacts to visibility.  Due to the funding constraints, it was not possible for Alaska to perform photochemical grid modeling as part of the proposed Regional Haze SIP.  The modeling and other technical analyses performed are laid out in the proposed SIP, and the Department welcomes comments on the material provided and included in the SIP.

The current SO₂ requirements within the draft SIP reference the BACT for the nonattainment area in Fairbanks, and currently that nonattainment area BACT are not approved yet by the EPA, so they could change. And if they do change, and to the extent that they may even be removed, depending on what occurs within the next, you know, three to four months, if that were to occur, would the state have to revisit and redo a four-factor analysis for SO₂ for those facilities involved, or would just referencing the BACT alone, without any additional limits or regulatory requirements, be sufficient?

As noted in the question, EPA has not yet proposed an action with respect to the BACT determinations contained in the Fairbanks North Star Borough PM2.5 Serious State Implementation Plan (SIP).  The Department has proposed including those recent BACT analyses in the proposed Regional Haze SIP rather than requesting that owners of those facilities repeat that effort with updated analyses.  SIP BACT analyses are detailed, costly exercises to complete and should meet the Regional Haze planning requirements. The Department is awaiting EPA’s action on the PM2.5 BACT determinations and, as is the case with any SIP, will review those findings and take actions if needed.  SIPs can be amended through the state administrative regulatory process.  The Department welcomes any comments related to the Department’s approach in including the existing, current FNSB PM2.5 SIP BACT analyses and determinations in support of meeting the Regional Haze SIP requirements.

The Best Available Control Technology (BACT) analyses from the Fairbanks North Star Borough (FNSB) PM2.5 Serious State Implementation Plan (SIP) are being used in the Regional Haze SIP as well.  As EPA has not yet taken action on the BACT determinations in the PM2.5 SIP how could this impact the Regional Haze SIP?

Because the BACT analyses had been recently completed for several facilities for the PM2.5 Serious area SIP, the Department decided to use those recent analyses for the Regional Haze SIP rather than requesting that owners of those facilities repeat that effort with 4-factor analyses, as allowed by the August 20, 2019, RH guidance document.  SIP BACT analyses are detailed, costly exercises to complete and, as long as they were conducted after July 31, 2013, are sufficient to meet the Regional Haze planning requirements.  The use of these recent analyses also ensured that the State has provided consistent data for the sources in question and acknowledged the emission limits that are being implemented for the various emissions units for the purpose of reducing fine particulate matter and its precursor emissions in support of attaining the National Ambient Air Quality Standards.  Where new data or information was available, that was also included in the analysis provided in the proposed Regional Haze Plan.  While it is true that EPA has not yet taken action on those FNSB PM2.5 BACT determinations they are effective in state regulation, and the analyses are the best information the Department has for evaluation and inclusion in this Regional Haze SIP.  DEC is awaiting EPA’s action on the PM2.5 BACT determinations and, as is the case with any SIP, will review those findings and take actions if needed.  SIPs can be amended through the state administrative regulatory process.  The Department welcomes any comments related to the Department’s approach in including the existing, current FNSB PM2.5 SIP BACT analyses and determinations in support of meeting the Regional Haze SIP requirements.

Additional information:

You may submit written questions relevant to the proposed action to DEC by submitting questions electronically via our public notice site at https://dec.alaska.gov/comment/, under the Notice and Link to Comment section, by May 11, 2022.  Alternately, you may submit questions to Rebecca Smith at rebecca.smith@alaska.gov.

The department will aggregate its response to substantially similar questions and make the questions and responses available on this page.  The department may, but is not required to, answer written questions received after the May 11, 2022, deadline for submitting questions.

Documents for the proposed regulation changes may be found at: 2022 Regional Haze Regulations Webpage

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