Grants Pass and Klamath Falls PM10 Maintenance Plans and

Associated New Source Review Rule Amendments

Outline - EQC meeting:

Talk to Andy - How does this fit into the AQ overview? Show chart and identify location of the maintenance planning process to AQ overview in the chart.

1.  What is proposed?

•  Grants Pass and Klamath Falls PM10 Maintenance Plan.

•  Rules associated with New Source Review for Industrial Sources.

•  Request from EPA to Redesignate these areas as PM10 Attainment Areas (State Designation "Maintenance" Area).

•  Temporary Rule to extend the date for ozone precursor significant impact distance extension. This will provide time to write rules for ozone precursors and their significant impact distance.

2.  Why is the rulemaking important?

•  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 to continue the protection of the airshed in addition providing additional flexibility to the stringent nonattainment area rules for industrial sources.

•  Redesignation of these areas satisfies most these concerns.

•  Since Division 225 was open in this rulemaking, the temporary rule will provide the department time to write rules for ozone precursors.

3.  Attributes of the plans:

a.  Over ten years of no violations.

b.  The maintenance plans - 10 yr - continue the same emission reduction strategies proposed that helped bring Klamath Falls and Grants Pass into compliance

c.  Provides flexibility for transportation-related projects by planning for growth… To do this we allocate a certain amount of emissions for known transportation projects and have added extra emissions for unanticipated projects.

d.  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.

e.  Transmittal to EPA for approval and request for redesignation.

4.  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 city owned co-generation facilities and their PM2.5 impact. PM2.5 has merit, but is outside the scope of the rulemaking. In Klamath Falls case, the County established an ordinance that addresses PM2.5 for woodstoves and open burning as a pollution prevention action.

b.  Two offered support for DEQ's approach. The City of KFalls for our attempt to change the federal nonattainment status to attainment. SOTIA for providing flexibility in NSR rules with our unique approach to protecting the standard. Thanks.

5.  EPA commented by complimenting DEQ on their maintenance planning activities and offered some clarifying suggestions to the industrial NSR rules. DEQ will address EPA's suggestions.

6.  What's next? Aside from the submittal of the rules to the SOS, we will submit the plans to EPA for approval and request EPA redesignate both Grants Pass and Klamath Falls as a federally recognized attainment area.

7.  We request authorization to submit the plans and rules to EPA and request a EPA redesignate Grants Pass and Klamath Falls to the federal designation of attainment.