DRAFT

DCB Comments on Latest Draft Changes to OAR 340-224 and OAR 340-225

OAR 340-224

Comments to come.

OAR 340-225

Paragraph (2)(d) in 0020 Definitions needs to have the word “year” inserted between “calendar” and “2006.”

Paragraph (3) in 0020 Definitions needs to have the word “calendar” inserted before the second “year.”

The definitions of “Competing PSD increment consuming source impacts” and “Range of influence formula” need to be revised back to having a separate approach for analyses of impacts on Class I areas. The concept of a significant concentration gradient in the vicinity of the proposed source or modification is not relevant when defining the modeling domain for a Class I PSD increment analysis.

Regarding the change to the definition of “Source impact area” I need to check with the modelers to see if we are allowing something other than a circular area for purposes of defining the modeling region.

In 0060, I don’t see a provision that says what is required if subsection (2)(c) is not met. Both subsection (2)(b) and subsection (2)(d) say that they apply if the requirements of subsection (2)(a) are not met. The rule needs to include a provision that says what is required if the single source impact analysis test in (2)(c) is not net.

The reference to the significant impact levels in 0060(2)(c) should be to the Class II SILs since this provisions applies to AAQS and not increments. Of course, ODEQ can be more stringent and require that the impact be less than the Class I SILs.