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- - Draft - - PSD
Project Workgroup- Drafting Team |
Participants
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Dave Klemp, MT |
Randy Raymond, MO |
Bill Spires, ?? |
Topics
1. Background of PSD Guidance initiative
Dave Klemp summarized the workgroup's efforts to-date for the benefit of new participants. Based on the meeting in Denver, WESTAR has sent a letter to EPA (Bill Harnett) suggesting that EPA, the states, tribes and federal land management agencies work together on the development of guidance for boundary redesignations and increment tracking. Click here for a copy of the letter.
Dave's presentation to the WESTAR air directors at the fall Business Meeting in Santa Fe was well received, and resulted in an endorsement of the workgroup's recommendations to a) work on redesignation guidance with EPA, FLM's, tribes, and CenSARA states and b) sponsor a specialty conference on increment tracking. Participation from other states was welcomed.
2. "Baseline Area Redesignation" strawman draft
Dave explained that EPA has been working on criteria they will use to evaluate state boundary redesignation proposals. The following six issues were distilled from the Denver meeting as being the most important criteria EPA will used in their evaluation. Dave was seeking feedback from the drafting team on ways to flesh out what EPA expects from the states in response to these questions.
Question 1. What is the purpose behind the redesignation proposal?
The guidance should provide examples, but not limit a state to a fixed list of reasons behind a redesignation request. Several suggestions were discussed as examples: economic reasons, better ability to track increment consumption, more realistic area to model to assess the impacts of a potential source, etc.
Question 2. What are the air quality impacts?
There are a number of ways a state could show the air quality impacts of a proposed new source. EPA will need to provide the states with guidance on when a more rigorous demonstration is needed, versus a simple demonstration.
Question 3. Is the area a reasonable size from the perspective of basic air quality planning?
What constitutes a "reasonable size" varies from one region of the country to another, and for good reason. For some states, CMSAs make sense, while in other states, it may make more sense to use large geographic areas, or political boundaries. EPA will need to identify what they would view as unreasonable, or identify the criteria they will use to judge if a states proposal is reasonable.
Question 4. How much growth would be built into the baseline if you were to re-trigger?
When re-triggering a baseline, there is a certain amount of emissions growth that may need to be built into the new baseline area. The amount of this growth may vary from one state to the next and may depend on the amount of emissions growth a state or an area is experiencing. In some areas there may actually be emission decreases that would lower the baseline concentration for a re-triggered area. This issue was discussed with the group more direction from EPA is needed so states would know how much growth or decline in emissions is necessary to be included in this analysis.
Question 5. What is the impact of re-triggering on Class I areas??
There is a recognition that a proposal to redesignate baseline areas in an area near, or that includes a Class I area, is different than redesignating the boundaries of a Class II area that doesn't impact a Class I area. Where a Class I area is affected, the state would need to determine how re-triggering a baseline date could impact the Class I areas. Here again, as in question 2 above, EPA will need to provide the states with guidance on when a more rigorous demonstration is needed, versus a simple demonstration.
Question 6. What would this mean with respect to increment tracking, past and future?
When submitting a redesignation request, states need to describe how the redesignation request will impact how increment was and will be tracked. The group discussed that if a baseline area is re-triggered, it may then be easier, more meaningful, and a more efficient use of limited state resources to track increment. This outcome may be achieved because the areas requiring increment tracking will most likely be smaller than the previous areas.
3. Additional thoughts
The group discussed the value of including a preamble that provides the statutory and regulatory background of baseline area redesignations. Both EPA and the states have responsibilities, and the rules set some boundaries on what a state can and can't do.
Action Items
1. Dan Johnson and Dave Klemp will follow-up with Bill Harnett in the near future to gain EPA’s perspective on the issues mentioned above.
2. Pending the follow-up discussion
with Bill Harnett noted above, Dave Klemp and Dan Johnson will prepare an
initial draft of the policy document for review by the workgroup.