Title V NAAQS Modeling Strategy Update

Dick Cordes, P.E.,

Melissa Kuskie, and Jim Sullivan

Agenda

• Overview

• Summary of Stakeholder Engagement

• Project Status

• Moving Forward

• Contact Information

Bottom Line Up Front

• When to model (not “how”)

• Still Working on Complete Straw Proposal

– During development, recognized a two-phase process: • Selection strategy (When to model)

• Implementation strategy

Bottom Line

Project is still under way

• Project Purpose – Adjust the current Title V modeling strategy to

address the new NAAQS by making administrative and technical adjustments

• Objective – Work within existing regulatory framework

– Improve program decisions on “when to model”

• Mission-Supported Goal – “Protect and Enhance Human Health and the

Environment”

Background • Modeling for Part 70 permits based on pollutant-

specific annual emission thresholds – Initiated over two decades ago; revised since

then – Minnesota extends NAAQS demonstration to

non-PSD permits via rule and SIP • Few states in the country have this type of

air management program • Reflects the MPCA’s air management

program and authorities developed prior to the 1970 Clean Air Act

Current Conditions • Most recent administrative modification in 2011

• Modified “when to model” approach for the short-term NAAQS that provides a case-by-case basis that considers:

• Public interest

• Location in nonattainment or maintenance areas

• Emissions increases

• Existing modeling information

• Installation of non-emergency internal combustion engines

• Triggering PSD, NNSR, or environmental review

Project Details Why we are modifying the strategy • Infrastructure SIP • Historical modeling thresholds based on older NAAQS • Greater public scrutiny of routine permit actions

affecting “when to model.”

How we are revising the strategy • New strategy to address changes in NAAQS • Request input from public • Generate a straw proposal that includes public input • Ask for reactions to straw proposal • Pilot a “final” strategy • Review Pilot performance

Summary of Stakeholder Input

• Held input sessions at July 2015 Modeling Meeting

• Asked interested parties to submit their ideas and concerns; received three letters

• Three areas of input

– Administrative, Technical, and Legal

• Considering each issue as we develop the strategy

Administrative/Legal • Items within the Implementation Strategy

• Efficiency and risk

• Issues identified by Stakeholders

o Limit the use of discretionary modeling

oPermit reissuance is not an appropriate driver of modeling

oClearly define requirements

o Focus on actual emissions and clusters

• Work parallel with MPCA Environmental Review

– Currently coordinated

Selection Strategy based on stakeholder input

• Based on feedback from stakeholders, MPCA offers the following observations:

– Prefer a geographic selection approach (most consistent with external feedback and existing resources)

– Possible option to consider:

• Using MNRiskS

Technical/Administrative

Moving Forward

• The geographic approach option could be pursued as a selection strategy for the straw proposal

• Want stakeholder thoughts and ideas on the geographic approach and related options

• At a minimum, we would like to hear your thoughts on the following: – What do you think are some strengths/weaknesses of

a geographic approach? – Are there other options or selection alternatives we

should consider?

Contact Information

Permitting – Dick Cordes, P.E.

richard.cordes@state.mn.us

Modeling – Jim Sullivan

jim.sullivan@state.mn.us

Policy – Melissa Kuskie

melissa.kuskie@state.mn.us