The following are the comments from WV on the Draft BART Protocol

1.) In the draft protocol, the screening procedure states that the highest 
resulting deciview change from 3 years of modeling results will be used to 
determine a pass/fail of the screen, while the refined modeling procedure 
will use the regulatory procedure, which is the highest of the 3 years of 
modeling 98% deciview change (8th highest Annual).  This procedure may 
result in a overly conservative screening procedure in which few sources 
are eventually screened out.  VISTAS may wish to use a less conservative 
method, for example a "high-second high" procedure such is typically used 
in short term NAAQS standards.  This would ensure a conservative result 
(highest 2nd high in screening versus a regulatory highest 8th high in 
refined) but would allow the screening procedure to still be effective in 
the event of a single aberrant result due to intrinsic meteorological 
conditions or model limitations.

2.)The draft protocol solicits comments upon which method of deriving 
Ammonia concentrations should be used for use in the visibility calculation
s.  West Virginia supports the use of the spatially and temporally varying 
Ammonia fields derived from the 2002 CMAQ modeling runs.  These concentrati
ons should be used to calculate monthly ammonia averages at each of the 
Class I areas (averaged over the spatial extent of the Class I area) to be 
used in each of the 3 years of BART modeling runs.

3.)  West Virginia supports the use of the Ammonia Limiting Method (ALM) 
in both the screening and the refined visibility calculations, to more 
accurately determine the nitrate contribution to the visibility impact.

4.) West Virginia supports the creation of the VISTAS Class I Area 
subdomains based upon logical geographical groupings, with a grid cell 
size in the range of 3-4 kilometers.  While it is recognized that these 
subdomains may not be appropriate for every single source, especially 
those very close to the Class I Areas, or in very complex terrain and or 
wind flow conditions (land/sea interface), this method will provide the 
most cost effective approach to minimize the number of subdomains that 
would be useful to the maximum number of sources.

If you have any questions, please feel free to contact me.



Chris Arrington, P.E.
WV DEP - Division of Air Quality
601 57th Street SE
Charleston, WV 25304-2345
Phone: (304) 926-0499  ext 1355