1. Navajo Nation Air Quality Control Program Operating Permit Program Navajo Nation Environmental Protection Agency Route 112 North/Bldg. 2837 Fort Defiance, AZ 86504 FAX: (928) 729-4313 Phone: (928) 729-4096

2. Our Mission To protect and enhance the health and livelihood of Navajo people To protect and preserve the natural beauty and environment on the Navajo Nation To ensure the air emissions from the industries operating on the Navajo Nation are regulated

3. Overview  Navajo Nation Air Quality Control Program (CAA Section 105 Grant)  Monitors ambient air quality  Open Burn Regulations  Navajo Nation Operating Permit Program  Issues Title V permits to major sources on the Navajo Nation

4. Clean Air Act Amendments 1990 Title I Air Pollution and Control Title II Emission Standards for Moving Sources Title III General Title IV Acid Deposition Control Title V Permits Title VI Stratospheric Ozone Protection Clean Air Act, USC Title 42 Chapter 85

5. Title V Permit  A Title V permit grants a source permission to operate and includes all air pollution requirements that apply to the source, emissions limits, monitoring, record keeping, and reporting requirements in a single document.  Major Source Threshold in Attainment Areas PollutantAnnual Emissions ( tons/yr) VOC, NOx, SOx, CO, PM10100 Single HAP10 Combination of HAPs25

6. Purpose of a Title V Permit  To improve compliance and make enforcement easier by  Listing all application requirements in one document, including terms from NSR permits, in one document  Requires reporting and certifications  Adding source specific monitoring  Increasing public access to permit records  Making the term of Title V permit federally enforceable

7. Characteristic of an effective Title V permit Clearly identify the requirements that apply to the facility Requires the facility to perform monitoring to assure the public that facility is in compliance Provide the public with the ability to enforce permit conditions

8. Title V Sources on the Navajo Nation El Paso Natural Gas Compressor stations at: 1. Leupp 2. Dilkon 3. Navajo (Cornfields, AZ) 4. Window Rock 5. Gallup 6. White Rock Transwestern Pipeline Leupp Compressor Station Peabody Western Coal Company ConocoPhillips Wingate Fractionating Plant Resolute Aneth Unit APS Four Corners Steam Electric Station SRP Navajo Generating Station

9. Operating Permit Program (OPP) and the Clean Power Plan (CPP)  All federal requirements under the Clean Air Act will be incorporated in the Title V Permit and the permit will be issued by NNEPA-OPP  Revisions or reopening  Permit process – public notice or public hearing  Navajo Generating Station and Four Corners Power Plant are the two effected EGUs that are subject to the CPP.

10. Option 2012 Emissions Proposed Supplemental 2014 Final Rule 2015 ProposedAlternative Rate, lbs/MWh 2121198920341305 Mass Cap, Tons 31,416,87329,644,47730,260,66421,700,587 Average Annual Affected Source Mass Goals (Short Tons) State2022-20242025-20272028-2029 Interim (2022- 2029)Final (2030) Navajo Nation 26,449,39323,999,55622,557,74924,557,79321,700,587 The CPP has finalized both a rate and a mass based approach. Table 1 lists the rate and combined mass for the Navajo Nation (both Navajo Generating Station and Four Corners Power Plant) for 2012 actual, proposed in 2014 and finalized in 2015. Table 2 lists the mass based goals broken down by interim periods. Table 1: Table 2:

11. What the Navajo Nation is doing…  Developed a Navajo Nation Carbon Team  Representative from a variety of Navajo Nation Departments (NNEPA, Division of Natural Resources, NN Department of Justice)  Participating in Government to Government Consultations with EPA  Currently reviewing the proposed Federal Implementation Plan