APPLYING THE AOH REPORT IN MONTANA Bob Habeck June 2005 WRAP AOH Workgroup Meeting Seattle, WA

AOH Report: A lmost O ver Bob’s Mom’s H ead

BOB’S MOM

REGULATORY APPROACH OVERVIEW 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 review and issue BART Determination.BART burden on source – DEQ to review and issue BART Determination. TSD modeling to drive controls.TSD modeling to drive controls.

REGULATORY APPROACH (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 year RFP analysis – 2013.SIP due 2008 – ten year plan – 2018 – five year RFP analysis – Public meetings only when draft plan developed.Public meetings only when draft plan developed. BART and Smoke Management key.BART and Smoke Management key. AoH products to facilitate discussions – but not to make determinations.AoH products to facilitate discussions – but 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 contribution within state.Most contribution within state. Outside state, greatest impact to N. Absaroka, WY and Teddy Roosevelt NP, NDOutside state, greatest impact to N. Absaroka, WY and Teddy Roosevelt NP, ND Similar distribution for NitratesSimilar distribution for Nitrates MT CONTRIBUTION OUTSIDE STATE

How much does MT contribute to haze in N. Absaroka? 20%, 4%, or –10% ?How much does MT contribute to haze in N. Absaroka? 20%, 4%, or –10% ? Could MT mandate controls on sources based on this modeling?Could MT mandate controls on sources based on this 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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