APPLYING THE AOH APPLYING THE AOH REPORT IN MONTANAREPORT IN MONTANA

Bob Habeck Bob Habeck

June 2005June 2005

WRAP AOH Workgroup MeetingWRAP AOH Workgroup Meeting

Seattle, WASeattle, WA

AOH Report:

AlmostOver Bob’s Mom’sHead

BOB’S MOMBOB’S MOM

REGULATORY APPROACHREGULATORY APPROACHOVERVIEWOVERVIEW

• Authority to Regulate (have).Authority to Regulate (have).

• Resources to Negotiate (some).Resources to Negotiate (some).

• Source by Source BART.Source by Source BART.

• Non-BART source analysis.Non-BART source analysis.

• BART burden on source – DEQ to BART burden on source – DEQ to review and issue BART Determination.review and issue BART Determination.

• TSD modeling to drive controls.TSD modeling to drive controls.

REGULATORY APPROACHREGULATORY APPROACH(continued)(continued)

• ““You Go First” Approach.You Go First” Approach.• Colorado begins domino effect.Colorado begins domino effect.• SIP due 2008 – ten year plan – 2018 – five SIP due 2008 – ten year plan – 2018 – five

year RFP analysis – 2013.year RFP analysis – 2013.• Public meetings only when draft plan Public meetings only when draft plan

developed.developed.• BART and Smoke Management key.BART and Smoke Management key.• AoH products to facilitate discussions – but AoH products to facilitate discussions – but

not to make determinations.not to make determinations.

•Percent contributions were as expected – No surprises.

•Model follows fairly well to what the monitor shows, but modeling is throwing in more Nitrates. However, it does follow a similar seasonal trend.

What’s Causing Haze in GNP?

Who’s Doing it?

•MT contribution 65%, 35%, or 12% ?

•Canada’s contribution 1%, 28%, or 14% ?

•OR / WA contribution 20%, 10%, or –1% ?

•Report discusses the differences between the models, but what is the conclusion or guidance for a state to draw a conclusion?

•Are either/both models defensible to stakeholders?

SULFATES

•Nitrates are mostly from Mobile Sources and are coming from outside the state.

•Question: Best way to explain “other”?

NITRATES

• Most Most contribution contribution within state.within state.

• Outside state, Outside state, greatest greatest impact to N. impact to N. Absaroka, WY Absaroka, WY and Teddy and Teddy Roosevelt NP, Roosevelt NP, ND ND

• Similar Similar distribution distribution for Nitratesfor Nitrates

MT CONTRIBUTION OUTSIDE STATE

• How much does How much does MT contribute to MT contribute to haze in N. haze in N. Absaroka? 20%, Absaroka? 20%, 4%, or –10% ?4%, or –10% ?

• Could MT Could MT mandate mandate controls on controls on sources based sources based on this on this modeling?modeling?

MT IMPACT ON WY

SIP Planning Timeline

CONCLUSION

• Montana believes defensibility of products to be a high priority before taking steps toward deciding on control strategies.

•AoH report is highly useful tool to be used in conjunction with additional modeling and inventory work – conclusions cannot be drawn on results of AoH report alone.

•Results from modeling the effects of Federal Programs (i.e. mobile sources), Smoke Management Programs, and application of BART will better define what the next steps are

•Attribution to specific sources or source categories may be required in the future (especially for Eastern Montana sites).

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