“The BART Guidelines provide that we may use the CALPUFF…modeling system or another appropriate model to predict the visibility impacts from a single source on a Class I area… The BART Guidelines indicate that a modeling protocol be developed for determining individual source attributions. The State of Hawaii‟s contractor, Alpine Geophysics, developed a protocol, which was reviewed by the State of Hawaii and EPA.33 Although the BART Guidelines recommend use of a minimum of three years of mesoscale meteorological model output for conducting this type of analysis, only one year (2005) of mesoscale meteorological data was available at the time this protocol was developed.34 Therefore, emissions were modeled over a one-year period using the 2005 mesoscale meteorological data.” [p. 41]
**Perhaps three years of data should be used, since there were increases from 2005 to 2008 in these categories (see Tables 8 and 10, p. 34-35]
NO 2-- aircraft
S0 2-- area sources, aircraft, in and near port marine
VOC—area sources, aircraft, in and near port marine
PM—area sources, in and near port marine
NH 3—on road mobile sources
[comment based on DRAFT Approval and Promulgation of Implementation Plans; State of Hawaii; Regional Haze Federal Implementation Plan]
Comment from Cory Harden
This is comment on Proposed Rule
Approvals and Promulgations of Implementation Plans: Hawaii; Regional Haze Federal Implementation Plan
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