Issue

Options

PROs

CONs

Net Air Quality Benefit

•  Option 1A: Define NAQB as 1:1 offset ratio for all sources based on CA rules

•  Option 1B: Define NAQB as greater than 1:1 offset ratio for all sources

•  Option 2: 1A or 1B for non-federal majors and retain current version of NAQB for federal majors sources but eliminate “less than a significant impact level increase at all modeled receptors”

•  Eliminate “less than a significant impact level increase at all modeled receptors” problem

•  Backsliding

“Small” scale local energy project – what is “small?”

•  Not needed if we eliminate NAQB

•  Energy Facility Siting Council:

The following types of energy facilities must have a site certificate from the Council before construction:

◦  Electric power plants with a nominal electric generating capacity of 25 megawatts or more from thermal power or combustion turbines.

•  Consistent with most other programs

•  Emissions ~30 tpy PM_2.5

Areas violating NAAQS but not yet designated NAA – where DEQ has determine the background concentration levels are above the standard through monitoring

•  Federal Major sources are excluded because that would change the federal PSD program

•  For non-federal major sources only in the PSEL rules:

1.   Modeling < SIL – done

2.  Modeling > SIL:

a.  Offsets ratio of greater than 1:1 (TBD) and at least X% of offsets from sources or activities that are known to contribute the most of the NAAQS exceedance

b.  BACT

c.  Modeling for increment

•  Request NAA designation after buy-off from community

•  Could protect AQ in same way as if EPA had designated area NAA (need attainment plan)

•  Woodstove problem

Attainment Plan/Maintenance Plan Bridge (COLLIER)

After 3 years of monitoring showing attainment and continued monitored attainment:

•  Allow sources to construct under maintenance plan rule requirements before maintenance plan is approved

•  Limit to nonattainment non-federal majors (<100 tpy sources)

•  Promotes economic development

•  backsliding

Netting basis for sources that went through PSD before 2001

•  NB

•  Consistent with intent

•  No BACT

Change 40% opacity to 20% and require COMS

•  Leave as is

•  Visible emissions from the hog fuel boiler may exceed the general standard of 20% during periods of soot blowing and/or grate cleaning. Periods of excess emissions from soot blowing and/or grate cleaning are limited to not more than 15 minutes in any 8 consecutive hours.

•  sources happy

•  equity

•  embarrassment

•  none

Delete 3 minute aggregate opacity limit and use 6-minute averages (EPA Method 9)

•  Leave as is

•  Line up standard with reference test method

•  Simplifies monitoring conditions in TV permits

•  Backsliding

•  EPA stringency demonstration

Change 0.2 gr/dscf to 0.10 gr/dscf and add 3 year compliance schedule

•  Leave as is

•  sources happy

•  embarrassment

Exempt sources with specific standards from general grain loading/opacity standards- (add more substantive provisions for O&M during startup/shutdown and add provision for source to prove that emissions during startup/shutdown do not violate NAAQS through modeling if necessary to appease EPA)

•  Leave as is

•  Simplifies monitoring conditions in TV permits

•  Reduces DEQ workload regarding unavoidable excess emissions

•  Backsliding

•  EPA stringency demonstration (during startup/

shutdown)

Splitting Sources – not retroactive

•  Same SIC – split NB evenly or proportionately

•  2 different SICs – NB stays with original SIC and cannot be split and the new SIC is a new source

•  Aligns with majority of past guidance given to sources

•  PSD is not avoided

•  Perceived as detriment to economic development