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CHAPTERFOUR Responses to Public and Agency Comments Letter and Comment No. Resaonse not conducive to such photochemical reactions. At present, organic aerosol formation processes aze not well understood, and current modeling techniques aze not available for estimating visibility degradation. F-4.5 The text on page 4-26 has been corrected. The Prevention of Significant Deterioration (PSD) Class I and II increments were established by the U.S. Congress to limit the additional amount of selected air pollutants above existing (or baseline) levels from all new sources. Congress also provided for Federa! Land Manager review of potential Air Quality Related Value (AQRV) impacts, regazdless of the level of predicted PSD Increment Consumption. For PSD Class I azeas, the Federal Land Manager may certify that AQRV impacts would be acceptable even if the PSD Class I increments are predicted to be exceeded. However, PSD Class II increments aze never to be exceeded, regazdless of the level of potential AQRV impacts. Finally, the determination of PSD increment consumption is a regulatory agency responsibility conducted as part of the New Source Review process, and is not required under NEPA. F-4.6 The CDPHE has approved the use of the one-year of meteorological data for the Yankee Gulch facilities New Source Review PSD permit analysis. The preparation of the EIS air quality impact analysis is a BLM responsibility under NEPA, and is not part of an air regulatory agency evaluation under the Clean Air Act. Regazdless of the analysis methods used, and the conclusions reached in the EIS, American Soda would be required to obtain necessary permits and comply with all applicable local, state and federal air quality laws, standards, and implementation plans. In addition, the project has completed a Level 2 analysis using CALPUFF/CALMET as described in the response to Comment F-4.1. F-4.7 Rounding of the calculations to compaze to regulatory requirements was accomplished in accordance with EPA guidance. This guidance indicates that numbers aze to be rounded (following ASTM procedures) to the same number of significant digits as presented in the standard. As a potentially affected Federal Land Manager, the USFS should focus its critical review of AQRV impacts predicted in the New Source Review PSD permit application, as required under the Clean Air Act. In addition to the Level 1 screening visibility impact analysis reported in the Draft EIS text has been added to page 4-28 to describe the results of the Level 2 analysis as described in the response to Comment F-4.1. • 4-17