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.
Modeling – Jim Sullivan
Policy – Melissa Kuskie