Grants Pass and Klamath Falls PM10 Maintenance Plans and Associated New Source Review Rule Amendments

Outline - EQC meeting: (Have Andy explain how the process fits into the big picture, general maintenance and attainment planning, temporary rule making as an introduction)

1.  Two standards for particulate matter; EPA calls coarse and fine particulate matter standards. Coarse is less than 10 microns in size and fine is less than 2.5 microns in size. We are talking today about the coarse or 10 micron and less sized particulate matter.

2.  What is proposed? 4 items

1.  Grants Pass Particulate Matter (PM10) Maintenance Plan

2.  Klamath Falls Particulate Matter (PM10) Maintenance Plan.

3.  Rules associated with new or expanding industrial sources in maintenance areas.

4.  Request from EPA to formally redesignate these areas from PM10 "Nonattainment" to PM10 "Attainment" Areas (State Designation "Maintenance" Area)

3.  Why is the rulemaking important?

•  Because there have been over 10 years of exceedance free days, local governments and citizen groups have expressed desires for economic development, but at the same time have expressed the need to protect the airshed from exceeding the standards.

•  Maintenance plans have been developed address these issues.

•  We worked extensively with an advisory group in both communities. In both communities there were representatives of local governments, industry, citizen and environmental groups. Much of the work was an extension of the carbon monoxide maintenance planning we did two years ago for these communities. I would particularly like to recognize Chair Rob Pochert from the economic development group in Grants Pass for providing valuable leadership for that committee. I'd also like to recognize John Elliott, Klamath County Commissioner, for being instrumental in addressing the Klamath County air quality ordinance as part of the plan and fully participating in the Advisory Committee.

4.  Attributes of the plans:

a.  The maintenance plans - 10 yr - continue the same emission reduction strategies that brought Klamath Falls and Grants Pass into compliance with the coarse particulate matter standard

b.  Provides flexibility for transportation-related projects by planning for growth.

c.  Provides some flexibility for industrial sources for sources over 15 tons of PM10 by planning for some emissions increase, accommodating growth, but still maintaining the standard.

5.  Results of Public Comment? Conducted hearings on June 25^th and July 15^th. There was no oral public testimony at either hearing. However, we did receive 4 written comments….

a.  The first concerned about the proposed Klamath Falls city owned co-generation facility and their fine particulate matter impact. The fine particulate matter has merit, but is outside the scope of the rulemaking because we are only addressing the coarse particulate matter standard. So far there are no violations of the fine particulate standard.

b.  Both the City of Klamath Falls and Southern Oregon Timber Industries Assn offered support for DEQ's approach. Thanks.

c.  EPA commented by complimenting DEQ on their maintenance planning activities and offered some clarifying suggestions to the industrial New Source Review rules. To further clarify our rules addressing EPA’s concern we offer the following errata page to address Standards and effects on wilderness areas from maintenance area industrial sources. Please go to Division 222 Section 0041(3)(b)(C). We suggest inserting the word maintenance in this sentence. DEQ addressed other EPA's suggestions. We checked with EPA and they are satisfied with our response.

6.  What's next?

a.  Submit the rules to the SOS

b.  Submit the plans including rules to EPA for approval and

c.  Request EPA redesignate both Grants Pass and Klamath Falls as a federally recognized attainment area.

7.  We request the EQC to adopt the plans, the rules and request federal redesignation.

8.  Questions?