1. Who is BART in Idaho and how do we know?

2. BART Eligible in Idaho? WRAP Contractor early identification
Review of SIC codes against 26 BART categories
Reviewed construction and operation dates of units
Combined facility/units to determine 250 tpy threshold of SOx, NOx or PM.
WRAP contractor Identified several sources as in and several that were maybe in.
We reviewed the sources and found on facility had by miss categories and several facilities that were out because of age or emissions.
We ended up with seven facilities that were eligible.
Potlatch 2-4) Amalgamated Nampa, Twin Falls, Paul, 5) Simplot Don Plant 6) P4/Monsanto 7) Agrium 8) Ashgrove Cement- later determined Ashgrove was preBART

3. BART the Problem Child! EPA BART guidance – what to do?
Lack of authority to implement – develop rules
EPA BART guidance – what to do?
Idaho’s complex terrain – how to model?
Once we were ready to begin the BART process we realized we didn’t have the authority to implement Regional Haze or BART. Through the negotiated rule making process we have a proposed rule that will provide the authority to: Implement BART
establishes a .5 deciview threshold for BART subject.
establish Long Term Strategies/control measures
ability to set Reasonable Progress Goals for Class I areas within Idaho
There was a struggle on who to deal with EPA’s BART guidance – should be incorporate into our rule or simply follow as guidance. Decided to implement the basics from early parts of Regional Haze Rule and the .5 deciview threshold as identified in the rule.
Because of the complex terrain in Idaho, the WRAP regional model didn’t seem like a good fit for our BART subject modeling. We worked with Oregon, Washington and EPA to develop a 3 year met coverage at 4 km and a 3-state modeling protocal.
And now we think there are 4 BART sources. 1 Boiler at each of the Amalgamated facilities and P4

4. BART Needs The Clearing House – WRAP assistance Consultation with FLMs
Need to wrap BART up
end of the year deadline for controls and associated emission reductions
Modeling Center models BART reductions
We like the idea of the BART clearing house. As we move forward on the Amalgamated boilers we need to make sure we are being consistent with the reductions made at similar facilities in other states.
We will need a forum and process to work with the FLMs to make sure they are in agreement with the BART findings.
Most of all we need to “wrap” BART up. We need to make the BART determinations by the end of the year and get the associated emission reductions to the Regional Modeling Center so we can model. We need this model done so we have a better idea on where we will be setting the Reasonable Progress Goals.

5. Thanks!