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analysis of the impacts is still valid and is incorporated by reference for disclosing the <br />cumulative power station impacts. A brief description of EPA's Statement of Basis (SOB) <br />describing the modeling analysis and results follows. <br />A modeling protocol was submitted and methodologies were approved by the EPA and federal <br />land managers (National Park Service, BLM). A dispersion model analysis was conducted for <br />NAAQS compliance and PSD Class II increment compliance, and consisted of two phases: (1) a <br />near field analysis for pollutants with emission rates above PSD significance levels including <br />(CO, NO2,SO2, & PMIo), and (2) a full impact analysis. For each pollutant, results of the near <br />field analysis determine whether a full- impact analysis is needed for that pollutant. Near field <br />analysis was performed to determine pollutant concentrations at the fence line and beyond for the <br />proposed WCFU alone. A full- impact analysis was performed to determine pollutant <br />concentrations (S02 and PM 10) from all sources (including Bonanza Unit 1) within and around <br />the area of impact, and at Class I areas (far - field), for compliance with NAAQS and PSD Class I <br />and II increments. Additional modeling analyses were also performed as part of the far -field <br />analysis, to ascertain the impact on regional haze (i.e., visibility), plume blight, and deposition at <br />the Class I areas in Utah, Colorado, and Wyoming. <br />In short, the results of the modeling analysis were within the required guidelines for PSD <br />permitting (40 CFR 52.21(k)) such that the EPA issued the permit. The original SOB is available <br />on the EPA's web site (http: / /www.epa. og v /regionS /air /) for further reading. The EPAs <br />cumulative far -field review incorporated the existing Unit 1 and proposed WCFU emissions in <br />its analysis, which would be ultra conservative as compared to just the existing Unit 1's <br />emissions alone (it is unforeseeable as to whether or not the WCFU will actually be constructed <br />at this time). The BLM's concern for the cumulative effects of coal combustion is primarily for <br />PM 10 (the major component of the Proposed Action's emissions profile). According to the EPA's <br />review, the `affected area' for PMIo would not extend beyond a few miles away from the <br />Bonanza Power Station, and thus would not include the Deserado Mine's location. Therefore <br />cumulative impacts of PMIo in the Proposed Action area should be minimal. Further, the EPA, <br />not the BLM is the regulatory authority that authorizes emissions and controls implementation <br />for this source. The BLM has no authority to require controls, monitoring, or reporting for <br />emissions resulting from the sources operation, and therefore no further analysis for this source <br />will be completed. <br />With respect to oil shale development, the technologies to extract this potential energy source are <br />not yet proven, and therefore any future impacts (cumulatively or otherwise) associated with its <br />development are too speculative to consider in this EA. However, the BLM is currently <br />preparing a Programmatic EIS to address potential issues associated with oil shale development <br />that may be beneficial to the reader when finalized. Project specific impacts from oil shale <br />development will be evaluated when the economic viability of the resource is proven and <br />reasonable alternatives for NEPA analysis can be developed. <br />Mining activities as well as other stationary sources of pollution related to air emissions are <br />permitted by the Air Pollution Control Division of the CDPHE. The State imposes permitting <br />limits and control measures in order to limit emissions of NAAQS pollutants. The State develops <br />air quality attainment and maintenance plans in order to keep Colorado in compliance with the <br />DOI- BLM -CO- 110- 2012- 0023 -EA 29 <br />