Under the Regional Haze Rule, each state must set "reasonable progress goals" toward improving visibility in Class I areas and develop a plan to meet these goals. Idaho must decide which of two strategies it will implement to address emissions from large, industrial sources: Best Available Retrofit Technology (BART) or emissions trading.

BART requires facilities meeting certain requirements to install control technologies that reduce haze-causing emissions. These technologies are different for each industry and process, but are collectively referred to as best available retrofit technology or BART. The other alternative, emissions trading, is a market-based approach which allows facilities to work together to achieve reductions in haze-forming pollution.

Under BART, states must evaluate stationary sources of air pollution to determine:

• Eligibility: Is the facility a BART-eligible source? To be eligible, a facility or an emissions source at a facility must fall into one of 26 sector categories, be built between 1962 and 1977, and emit more than 250 tons of a haze-causing pollutant. Common BART eligible sources may include coal-fired boilers, pulp mills, refineries, phosphate rock processing plants, and smelters. Why does BART apply only to facilities built between 1962 and 1977?

• Subject: Assuming a facility meets the eligibility criteria, the state must determine if the source or group of sources causes or contributes to regional haze in a Class I area. This is done through air quality models which show how emissions from a specific source disperse and affect a geographic area.

• Determination: Once a source is determined to be eligible and subject to BART, the state must evaluate what available technologies or controls can be used to reduce haze-causing pollutants. In making this determination, the state must consider: the cost of compliance, energy, and non-air environmental impacts; existing controls at source; the remaining useful life of the source; and the visibility improvement reasonably expected from the technology.

Advantages to BART include:

•  Widespread applicability. Many states are expected to implement BART. Companies that have facilities in multiple states may wish to install similar technologies at multiple plants at the same time.

•  With control technologies, actual emissions can be estimated so companies can demonstrate their role in reducing emissions.

•  BART may be costly to implement at some facilities.

•  If visibility does not improve, facilities may be required to install additional controls, or other sources of emissions may be required to reduce emissions.

•  If a new facility is built that emits haze-causing pollution, it would not be subject to this rule and could degrade visibility further, placing a larger burden on existing facilities.

Idaho DEQ has been working with Oregon DEQ and Washington Department of Ecology (DOE) to develop a three-state modeling protocol for BART analysis under the Regional Haze Rule. The protocol, through the collaboration process, achieves the following objectives:

• A streamlined and consistent approach in determining which BART-eligible sources are subject to BART.
• Clearly delineated modeling methodology.
• A common CALMET/CALPULL/CALPOST/POSTUTIL modeling configuration.

The BART modeling protocol is currently open for comment by interested stakeholders. Link to protocol and associated documents below. Comments are due by 5 p.m. MST, Friday, June 9, 2006, and should be submitted to

Mary Anderson

Idaho DEQ

1410 N. Hilton

Boise, ID 83706

For more information, contact Mary Anderson at (208) 373-0202 or Mike Edwards at (208) 373-0438.