DIVISION 225

AIR QUALITY ANALYSIS REQUIREMENTS

340-225-0010

Purpose

This division contains the definitions and requirements for air quality analysis. This division does not apply unless a rule in another division refers to this division or a rule in this division. For example, division 224, New Source Review, refers the reader to provisions in this division for specific air quality analysis requirements.

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01

340-225-0020

Definitions

The definitions in OAR 340-200-0020, 340-204-0010 and this rule apply to this division. If the same term is defined in this rule and OAR 340-200-0020 or 340-204-0010, the definition in this rule applies to this division.

(1) "Allowable emissions" means the emissions rate of a stationary source calculated using the maximum rated capacity of the source (unless the source is subject to federally enforceable limits which restrict the operating rate, or hours of operation, or both) and the most stringent of the following:

(a) The applicable standards as set forth in 40 CFR Parts 60, 61, 62 and 63;

(b) The applicable SIP emissions limitation, including those with a future compliance date; or

(c) The emissions rate specified as a federally enforceable permit condition.  

(2) "Baseline concentration" means:

(a) Except as provided in subsection (c), the ambient concentration level for sulfur dioxide and PM10 that existed in an area during the calendar year 1978. Actual emission increases or decreases occurring before January 1, 1978 must be included in the baseline calculation, except that actual emission increases from any major source or major modification on which construction commenced after January 6, 1975 must not be included in the baseline calculation;

(b) The ambient concentration level for nitrogen oxides that existed in an area during the calendar year 1988.

(c) For the area of northeastern Oregon within the boundaries of the Umatilla, Wallowa-Whitman, Ochoco, and Malheur National Forests, the ambient concentration level for PM10 that existed during the calendar year 1993. DEQ may allow the source to use an earlier time period if DEQ determines that it is more representative of normal emissions.

(d) For PM10 in the Medford-Ashland AQMA: the ambient PM10 concentration levels that existed during the calendar year 2006, the year that EPA redesignated that AQMA to attainment for PM10.

(e) The ambient concentration level for PM2.5 that existed in an area during the calendar year 2007.

(f) If no ambient air quality data is available in an area, the baseline concentration may be estimated using modeling based on actual emissions for the years specified in subsections (a) through (e).

(##) “Baseline concentration year” means the year used to determine the baseline concentration for a particular regulated pollutant in a particular designated area.

(3) "Competing PSD increment consuming source impacts" means the total modeled concentration above the modeled baseline concentration resulting from increased and decreased emissions of all other sources since the baseline concentration year that are expected to cause a significant concentration gradient in the vicinity of the source. Determination of significant concentration gradient may take into account factors including but not limited to ROI formula, spatial distribution of existing emission sources, topography, and meteorology. Allowable emissions may be used as a conservative estimate of increased emissions, in lieu of actual emissions, in this analysis. 4) "Competing AAQS source impacts" means total modeled concentrations OF THE SUBJECT POLLUTANT resulting from allowable emissions of all other sources expected to cause a significant concentration gradient in the vicinity of the source or sources under consideration. Determination of significant concentration gradient may take into account factors including but not limited to ROI formula, spatial distribution of existing emission sources, topography, and meteorology.

(5) "FLAG" refers to the Federal Land Managers' Air Quality Related Values Work Group Phase I Report — REVISED, published at 75 Federal Register 66125, October 27, 2010.

(6) "General background concentration" means impacts from natural sources and unidentified sources that were not explicitly modeled, and may be determined based on either site-specific ambient monitoring or, with DEQ approval, on representative ambient monitoring from another location.

(7) "Nitrogen deposition" means the sum of anion and cation nitrogen deposition expressed in terms of the mass of total elemental nitrogen being deposited. As an example, nitrogen deposition for NH4NO3 is 0.3500 times the weight of NH4NO3 being deposited.

(8) "Predicted maintenance area concentration" means the future year ambient concentration predicted by DEQ in the applicable maintenance plan as follows:

(a) The future year (2015) PM10 concentrations for the Grants Pass UGB are 89 µg/m3 (24-hour average) and 21 µg/m3 (annual average).

(b) The future year (2015) PM10 concentrations for the Klamath Falls UGB are 114 µg/m3 (24-hour average) and 25 µg/m3 (annual average).

(c) The future year (2025) PM10 concentrations for the Lakeview UGB are 126 µg/m3 (24-hour average) and 27 µg/m3 (annual average).

(9) "Range of influence formula” or “ROI formula" means the distance in kilometers from the source impact area or from the source, if there is no source impact area, that defines the boundary of the area estimated to be affected by the source’s emissions. Any location that is closer to the source than the ROI may be considered to be “within the range of influence” of the source. ROI is calculated as follows: :

(a) ROI (km) = Q (tons/year) / K (tons/year km).

(b) Definition of factors used in paragraph (A):

(A) Maximum ROI is 50 km.

(B) Q is the emission rate of the source in tons per year.

(C) K (tons/year km) is a regulated pollutant specific constant as follows:

(i) For PM2.5, PM10, SOx and NOx, K = 5;

(ii) For CO, K = 40; and

(iii) For lead, K = 0.15.

(10) “Single source impact” means the modeled impacts from an increase in emissions of regulated pollutants from a source without including the impacts from other sources.

(12) "Source impact area" means an area where predicted impacts from the source or modification equal or exceed the Class II significant impact levels set out in OAR 340-200-0020. This definition only applies to PSD Class II areas and is not intended to limit the distance for PSD Class I modeling.

(13) "Sulfur deposition" means the sum of anion and cation sulfur deposition expressed in terms of the total mass of elemental sulfur being deposited. As an example, sulfur deposition for (NH4)2SO4 is 0.2427 times the weight of (NH4)2SO4 being deposited.

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01; DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 12-2002(Temp), f. & cert. ef. 10-8-02 thru 4-6-03; Administrative correction 11-10-03; DEQ 1-2004, f. & cert. ef. 4-14-04; DEQ 1-2005, f. & cert. ef. 1-4-05; DEQ 9-2005, f. & cert. ef. 9-9-05; DEQ 10-2010(Temp), f. 8-31-10, cert. ef. 9-1-10 thru 2-28-11; Administrative correction, 3-29-11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11

340-225-0030

Procedural Requirements

When required to conduct an air quality analysis under this division:

(1) The owner or operator of a source must submit a modeling protocol to DEQ and have it approved before submitting a permit application; and

(2) In addition to the requirements defined in OAR 340-216-0040 for permit applications, the owner or operator of a sourcemust submit all information necessary to perform any analysis or make any determination required under this division. Such information may include, but is not limited to:

(a) Emissions data for all existing and proposed emission points from the source or modification. This data must represent maximum emissions for the averaging times by regulated pollutant consistent with the ambient air quality standards in OAR 340 division 202.

(b) Stack parameter data, height above ground, exit diameter, exit velocity, and exit temperature, for all existing and proposed emission points from the source or modification;

(c) An analysis of the air quality and visibility impact of the source or modification, including meteorological and topographical data, specific details of models used, and other information necessary to estimate air quality impacts; and

(d) An analysis of the air quality and visibility impacts, and the nature and extent of all commercial, residential, industrial, and other source emission growth, that has occurred since the baseline concentration year in the area the source or modification would significantly affect.

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01; DEQ 10-2010(Temp), f. 8-31-10, cert. ef. 9-1-10 thru 2-28-11; Administrative correction, 3-29-11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11

340-225-0040

Air Quality Models

All modeled estimates of ambient concentrations required under this division must be based on the applicable air quality models, data bases, and other requirements specified in 40 CFR Part 51, Appendix W, "Guidelines on Air Quality Models (Revised)." Where an air quality impact model specified in 40 CFR Part 51, Appendix W is inappropriate, the methods published in the FLAG are generally preferred for analyses in PSD Class I areas. Where an air quality impact model other than that specified in 40 CFR Part 51, Appendix W is appropriate in PSD Class II and III areas, the model may be modified or another model substituted. Any change or substitution from models specified in 40 CFR Part 51, Appendix W is subject to notice and opportunity for public comment and must receive prior written approval from DEQ and the EPA.

[Publications: The publications referenced in this rule are available from the agency.]

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01

340-225-0045

Requirements for Analysis in Maintenance Areas

Modeling: For determining compliance with the maintenance area limits established in OAR 340-202-0225, the following methods must be used:

(1) For each maintenance pollutant, a single source impact analysis is sufficient to show compliance with the maintenance area limits if:

(a) The modeled impacts from emission increases equal to or greater than a SER above the netting basis due to the proposed source or modification being evaluated are less than the Class II Significant Impact Levels specified in OAR 340-200-0020; and

(b) The owner or operator provides an assessment of factors that may impact the air quality conditions in the area showing that the SIL by itself is protective of the maintenance area limits. The assessment must take into consideration but is not limited to the following factors:

(A) The background ambient concentration relative to the maintenance area limit;  

(B) The emission increases and decreases since the area was designated as a maintenance area from all other sources within the range of influence of the source; and

(C) Other factors such as spatial distribution of existing emission sources, topography, and meteorological conditions.

(2) If the requirement in section (1) is not satisfied, , the owner or operator of a proposed source or modification must complete a competing source analysis to demonstrate that modeled impacts from the proposed increased emissions plus competing source impacts, plus the predicted maintenance area concentration are less than the maintenance area limits in OAR 340-202-0225 for all averaging times.

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A, 468A.025 & 468A.035
Hist.: DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 1-2005, f. & cert. ef. 1-4-05; DEQ 10-2010(Temp), f. 8-31-10, cert. ef. 9-1-10 thru 2-28-11; Administrative correction, 3-29-11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11

340-225-0050

Requirements for Analysis in PSD Class II and Class III Areas

Modeling: For determining compliance with the ambient air quality standards, PSD increments and other requirements in PSD Class II and Class III areas, the following methods must be used:

(1) For each regulated pollutant, a single source impact analysis is sufficient to show compliance with the ambient air quality standards and PSD increments if:

(a) The modeled impacts from emission increases equal to or greater than a SER above the netting basis due to the proposed source or modification being evaluated are less than the Class II significant impact levels specified in OAR 340-200-0020; and

(b) The owner or operator provides an assessment of factors that may impact the air quality conditions in the area showing that the SIL by itself is protective of the ambient air quality standards and PSD increments. The assessment must take into consideration but is not limited to the following factors:

(A) The background ambient concentration relative to the ambient air quality standards; and

(B) The emission increases and decreases since the baseline concentration year from other sources that are expected to cause a significant concentration gradient in the vicinity of the source. Determination of significant concentration gradient may take into account factors including but not limited to ROI formula, spatial distribution of existing emission sources, topography, and meteorology.

(2) If the requirement in section (1) is not satisfied, the owner or operator of a proposed major source or major modification being evaluated must complete competing source analysis as follows:

(a) For demonstrating compliance with the PSD Class II and III increments (as defined in OAR 340-202-0210), the owner or operator of the source or modification must show that modeled impacts from the proposed increased emissions, above the modeled baseline concentration, plus competing PSD increment consuming source impacts above the modeled baseline concentration are less than the PSD increments for all averaging times; and

(b) For demonstrating compliance with the ambient air quality standards, the owner or operator of the source must show that the total modeled impacts plus total competing source impacts plus general background concentrations are less than the ambient air quality standards for all averaging times.

(3) The owner or operator of the source or modification must demonstrate that the proposed source or modification will not cause or contribute to a new violation of an ambient air quality standard or PSD increment even if the single source impact is less than the significant impact level, in accordance with OAR 340-202-0050(2).

(4)The owner or operator of a source or modification also must provide an analysis of

(a) The impairment to visibility, soils and vegetation that would occur as a result of the source or modification, and general commercial, residential, industrial and other growth associated with the source or modification. As a part of this analysis, deposition modeling analysis is required for sources emitting heavy metals above the SERs as defined in OAR 340-200-0020. Concentration and deposition modeling may also be required for sources emitting other compounds on a case-by-case basis; and

(b) The air quality concentration projected for the area as a result of general commercial, residential, industrial and other growth associated with the source or modification.

[Publications: Publications referenced are available from the agency.]

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01; DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 1-2004, f. & cert. ef. 4-14-04; DEQ 10-2010(Temp), f. 8-31-10, cert. ef. 9-1-10 thru 2-28-11; Administrative correction, 3-29-11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11

340-225-0060

Requirements for For Analysis in PSD Class I Areas

For determining compliance with ambient air quality standards and PSD increments in PSD Class I areas, the following methods must be used:

(1) Before January 1, 2003, the owner or operator of a sourcemust model impacts and demonstrate compliance with standards and increments on all PSD Class I areas that may be affected by the source or modification.

(2) On or after January 1, 2003, the owner or operator of a sourcemust meet the following requirements:

(a) For each regulated pollutant, a single source impact analysis is sufficient to show compliance with PSD increments if modeled impacts from emission increases equal to or greater than a SER above the netting basis due to the proposed source or modification being evaluated are demonstrated to be less than the Class I significant impact levels specified in OAR 340-200-0020.

(b) If the requirement in subsection (a) is not satisfied, the owner or operator must complete competing source analysis to demonstrate that the increased source impacts above baseline concentration plus competing PSD increment consuming source impacts are less than the PSD Class I increments for all averaging times.

(c) For each regulated pollutant, a single source impact analysis is sufficient to show compliance with ambient air quality standards if modeled impacts from emission increases equal to or greater than a SER above the netting basis due to the proposed source or modification being evaluated are demonstrated to be less than the Class I significant impact levels specified in OAR 340-200-0020.

(d) If the requirement in subsection (c) is not satisfied, and background monitoring data for each PSD Class I area shows that the ambient air quality standards are more restrictive than the PSD increment, then the source must also complete competing source analysis to demonstrate compliance with the ambient air quality standards by showing that its total modeled impacts plus total modeled competing source impacts plus general background concentrations are less than the ambient air quality standards for all averaging times.

(e) The owner or operator also must demonstrate that the proposed source or modification will not cause or contribute to a new violation of an ambient air quality standard or PSD increment even if the single source impact is less than the significant impact levels under subsections (a) and (c), in accordance with OAR 340-202-0050(2).

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01; DEQ 11-2002, f. & cert. ef. 10-8-02; DEQ 10-2010(Temp), f. 8-31-10, cert. ef. 9-1-10 thru 2-28-11; Administrative correction, 3-29-11; DEQ 5-2011, f. 4-29-11, cert. ef. 5-1-11

340-225-0070

Requirements for Analysis of Air Quality Related Values Protection

(1) Non-federal major sources are exempt from the requirements of this rule.

(2) When directed by division 224, the requirements of this rule apply to each emissions unit that increases the actual emissions of a regulated pollutant above the portion of the netting basis attributable to that emissions unit.

(3) DEQ must provide notice of permit applications involving AQRV analysis to EPA and Federal Land Managers as follows:

(a) If a proposed major source or major modification could impact air quality related values, including visibility, DEPOSITION, AND OZONE IMPACTS within a Class I area, DEQ will provide written notice to the EPA and to the appropriate Federal Land Manager within 30 days of receiving such permit application. The notice will include a copy of all information relevant to the permit application, including analysis of anticipated impacts on Class I area air quality related values, . DEQ will also provide at least 30 days notice to EPA and the appropriate Federal Land Manager of any scheduled public hearings and preliminary and final actions taken on the application;

(b) If DEQ receives advance notice of a permit application for a source that may affect Class I area visibility, DEQ will notify all affected Federal Land Managers within 30 days of receiving the advance notice;

(c) During its review of source impacts on Class I area air quality related values, , pursuant to this rule, DEQ will consider any analysis performed by the Federal Land Manager that is received by DEQ within 30 days of the date that DEQ sent the notice required by subsection (a). If DEQ disagrees with the Federal Land Manager's demonstration, DEQ will include a discussion of the disagreement in the Notice of Public Hearing;

(d) As a part of the notification required in OAR 340-209-0060, DEQ will provide the Federal Land Manager an opportunity to demonstrate that the emissions from the proposed major source or major modification would have an adverse impact on air quality related values of any federal mandatory Class I area. This adverse impact determination may be made even if there is no demonstration that a Class I PSD increment has been exceeded. If DEQ agrees with the demonstration, it will not issue the permit.

(4) Visibility impact analysis requirements:

(a)The owner or operator must demonstrate that the potential to emit any regulated pollutant at a SER in conjunction with all other applicable emission increases or decreases, including secondary emissions, permitted since January 1, 1984 and other increases or decreases in emissions, will not cause or contribute to significant impairment of visibility on any Class I area.

(b) The owner or operator must conduct a visibility analysis on the Columbia River Gorge National Scenic Area if it is affected by the source;

(c) The owner or operator must submit all information necessary to perform any analysis or demonstration required by these rules.

(d) Determination of significant impairment: The results of the modeling must be sent to the affected Federal Land Managers and DEQ. The land managers may, within 30 days following receipt of the source's visibility impact analysis, determine whether or not significant impairment of visibility in a Class I area would result. DEQ will consider the comments of the Federal Land Manager in its consideration of whether significant impairment will result. If DEQ determines that significant impairment would result, it will not issue a permit for the proposed source.

(5) IN CONSULTATION WITH THE FEDERAL LAND MANAGERS UNDER FLAG, DEQ MAY REQUIRE a plume blight analysis or regional haze analysis.

(6) Criteria for visibility impacts:

(a) The owner or operator of a source, where required by division 224, is encouraged to demonstrate that their impacts on visibility satisfy the guidance criteria as referenced in the FLAG.

(b) If visibility impacts are a concern, DEQ will consider comments from the Federal Land Manager when deciding whether significant impairment will result. Emission offsets may also be considered. If DEQ determines that significant impairment would result, it will not issue a permit for the proposed source.

(7) Deposition modeling is required for receptors in PSD Class I areas and the Columbia River Gorge National Scenic Area where visibility modeling is required. This may include, but is not limited to an analysis of nitrogen deposition and sulfur deposition.

(8) Visibility monitoring:

(a) If division 224 requires visibility monitoring data, the owner or operator must use existing data to establish existing visibility conditions within Class I areas as summarized in the FLAG Report.

(b) After construction has been completed the owner or operator must conduct such visibility monitoring if DEQ requires visibility monitoring as a permit condition to establish the effect of the regulated pollutant on visibility conditions within the impacted Class I area.

(9) Additional impact analysis: The owner or operator subject to OAR 340-224-0060(2) or OAR 340-224-0070(3) must provide an analysis of the impact to visibility that would occur as a result of the proposed major source or major modification and general commercial, residential, industrial, and other growth associated with the major source or major modification.

(10) If the Federal Land Manager recommends and DEQ agrees, DEQ may require the owner or operator to analyze the potential impacts on other Air Quality Related Values and how to protect them. Procedures from the FLAG report should be used in this recommendation. Emission offsets may also be used. If the Federal Land Manager finds that significant impairment would result from the proposed activities and DEQ agrees, DEQ will not issue a permit for the proposed source.

Stat. Auth.: ORS 468.020
Stats. Implemented: ORS 468A
Hist.: DEQ 18-1984, f. & ef. 10-16-84; DEQ 14-1985, f. & ef. 10-16-85; DEQ 4-1993, f. & cert. ef. 3-10-93; DEQ 12-1993, f. & cert. ef. 9-24-93; Renumbered from 340-020-0276; DEQ 19-1993, f. & cert. ef. 11-4-93; DEQ 26-1996, f. & cert. ef. 11-26-96; DEQ 14-1999, f. & cert. ef. 10-14-99, Renumbered from 340-028-2000; DEQ 6-2001, f. 6-18-01, cert. ef. 7-1-01, Renumbered from 340-224-0110

.

Mark, 2014-03-11T18:11:00Z
*Division 225

Garrahan Paul, 2014-03-11T18:11:00Z
All of these references have been deleted from Division 222, so it no longer refers to Div. 225.

Garrahan Paul, 2014-03-11T18:11:00Z
I need to understand this better.

PCAdmin, 2014-03-31T12:27:00Z
fix

Garrahan Paul, 2014-03-31T09:27:00Z
I strongly advise against using the term “NAAQS” in these rules. In Division 202 you have adopted ambient air quality standards applicable in Oregon. They are compliant with the NAAQS (as they must be), but it is Oregon’s adopted standards that apply here. Nowhere in Oregon’s rules do you specify what NAAQS means. You do list the term in OAR 340-200-0025 to describe what the acronym stands for, but you never describe its substantive meaning. I am not going to redline every instance that you use the term in this division, but I don’t think it should be used at all. Alternatively, you should include it as a defined term—although really I think you should define the term AAQS with reference to Division 204 or call it the Oregon AAQS.

USE AAQS INSTEAD OF NAAQS EVERY TIME THIS DEFINITION IS USED.

Garrahan Paul, 2014-03-11T18:11:00Z
Concentrations of what?

Garrahan Paul, 2014-03-11T18:11:00Z
What does this mean? What is “significant”? What is a “gradient”?

Garrahan Paul, 2014-03-11T18:11:00Z
Too vague. Needs more definition. I know the intent is to provide some flexibility, but I think you would be better served by describing what you mean here more specifically—at least describe the basis on which you will determine the applicable “vicinity.”

Garrahan Paul, 2014-03-31T13:50:00Z
Starting here this all gets exceptionally confusing and unclear, and I’m convinced that it doesn’t have to be. I would like to just sit down with the staff that implements these analyses and walk through what they do, and I’m confident we can edit this to make it much more clear and defensible.

Garrahan Paul, 2014-03-11T18:11:00Z
I thought

Garrahan Paul, 2014-03-11T18:11:00Z
You have to describe what this means.

Garrahan Paul, 2014-03-11T18:11:00Z
I think you need to provide more limitations than this.

Garrahan Paul, 2014-03-11T18:11:00Z
I don’t follow why this is referenced here. Isn’t all of the rest of this rule focused on compliance with the 202-0225 maintenance area limits? I recommend that this be deleted and that sources be referred directly to those provisions wherever appropriate under Div. 224.

Garrahan Paul, 2014-03-11T18:11:00Z
“Maintenance pollutant” is a defined term.

Garrahan Paul, 2014-03-11T18:11:00Z
If you are going to use this term and the companion term “single source impact” I recommend that you define them.

Garrahan Paul, 2014-03-11T18:11:00Z
“Regulated pollutant” definition includes all criteria pollutant precursors.

PCAdmin, 2014-03-31T12:24:00Z
fix

Garrahan Paul, 2014-03-11T18:11:00Z
Div. 224 is now the only division that refers to Div. 225. There is a reference in Div. 216, but it only refers to providing application information as required under Div. 225, i.e., only when Div. 224 requires it.

Garrahan Paul, 2014-03-31T14:32:00Z
I don’t understand the purpose of this modeling. These provisions do not provide any standards against which this modeling is judged.

Leave it

Garrahan Paul, 2014-03-11T18:11:00Z
Already provided in 0010.

PCAdmin, 2014-03-31T14:34:00Z
crosswalk

Garrahan Paul, 2014-03-11T18:11:00Z
I don’t understand what application of Class II SILs has to do with compliance in Class I areas—especially when you’ve already required that these increases not be more than than the lower Class I PSD increment. What am I missing here? Can’t we just delete all of this?

Garrahan Paul, 2014-03-11T18:11:00Z
Moved to its own section, below.

Garrahan Paul, 2014-03-11T18:11:00Z
What does this mean?

Garrahan Paul, 2014-03-11T18:11:00Z
The term “non-federal major source” is not defined. I recommend that you either define it, if you want to use it, or else not use it and return this language to its original form.

PCAdmin, 2014-03-31T12:58:00Z
CROSSWALK

Garrahan Paul, 2014-03-11T18:11:00Z
Is this something different from the ACRV analysis, or is it just part of that analysis?

Garrahan Paul, 2014-03-11T18:11:00Z
Must it explicitly reference a visibility impact analysis, or does a general reference to 225-0070 ACRV analysis suffice? Need to be clear here.

Garrahan Paul, 2014-03-11T18:11:00Z
You need to define what these terms mean, or reference standards for performing them.