PM2.5 NSR and Designations Bill Harnett WESTAR Spring Meeting April 2, 2007

Outline PM2.5 Implementation (NSR) PM2.5 Designations

Background on PM2.5 NSR PM2.5 NAAQS promulgated in 1997 PSD implementation guidance – issued by John Seitz in 1997 (Use PM10 as a surrogate) Designations effective April 2005 NNSR implementation guidance – issued by Steve Page on April 5, 2005 (PM10 surrogate) PM2.5 implementation rule proposed Nov. 1, 2005

Proposed NSR Provisions PM2.5 regulated under Subpart 1 Major source threshold 100 tpy Significant emissions rate for PM2.5 10 tpy Precursors SO2 always “in” as a precursor; NOX presumed “in” unless State demonstrates that NOX is not a significant contributor to PM2.5 or part of the transport problem VOC and ammonia presumed “out” unless State demonstrates otherwise. Ammonia is not a precursor in PM2.5 attainment areas.

Proposed NSR Provisions (2) Offsets 1:1 ratio Allow interpollutant trading statewide, regionwide, or on a permit basis Transition policy – For PSD continue PM10 surrogate policy until SIPs approved PM2.5 Increments, SILs and SMCs in a separate NPRM PM2.5 NSR Final Rule – Aug./Sept. 2007

PM2.5 Increments, SILs, and SMCs Increments Approaches § 166(a) % of NAAQS approach Similar to approach recently used to establish NO2 increments (a.k.a. safe harbor approach) § 166(f) equivalent increments approach 3 options each for SILs and SMCs Proposal scheduled August 2007

24-Hour PM2.5 Designations PM2.5 NAAQS was revised for the 24-hour PM2.5 standard only, lowered from 65 g/m3 to 35 g/m3. Effective date of the revised PM standards is 12/18/06. Section 107(d)(1) requirements for new designations: States must make recommendations no later than 12/18/07. EPA must notify States and Tribes of any modifications no later than 120 days prior to the final designations date. EPA is required to make final designations not later than 2 years after promulgation of the revised NAAQS (12/18/08); this date may be extended for up to 1 year if EPA has insufficient information to promulgate the designations (12/18/09).

Violations of Revised 24-Hour PM2.5 NAAQS Approximately 70 areas are violating the 2006 24-hour PM2.5 NAAQS (based on 2003-2005 monitoring data) 32 are in the 39 existing PM2.5 nonattainment areas Predominantly urban areas, with several smaller cities and non-urban areas (populations less than 100,000) All except 3 are in the Eastern U.S. 38 are “new” areas (those currently designated attainment for existing PM2.5 nonattainment areas) Mix of urban areas, smaller cities, and non-urban areas About 20 are in the Western U.S.

Areas/Sites Violating 24-Hour PM2.5 NAAQS – 2003-2005 Current nonattainment area violates new 24-hr NAAQS [32 areas] Current nonattainment area meets new 24-hr NAAQS [7 areas] Sites not in a current nonattainment area violate the new 24-hr NAAQS (59 sites) 59 sites are violating the new 24-hr standard and are NOT located in an existing nonattainment area. They are located in 38 different areas (34 in metro areas, 4 not in a metro area).

Key Issues for 24-Hour PM2.5 Designations Guidance Timing of final designations (see table) Monitoring data State recommendations should be based on 2004-2006 data. Most recent 3 years of data will be considered when EPA makes final designations. Boundary recommendations: Based on the assessment of the same 9 factors in previous PM2.5 designations (see next slide). Case-by-case assessment versus presumption. For areas with existing PM2.5 NA boundary, justify if different 24-hour boundary recommended (not revisiting annual boundary).

Factors to Consider for Boundary Recommendations Emissions in areas potentially included versus excluded from the nonattainment area Air quality in potentially included versus excluded areas Population density and degree of urbanization including commercial development in included versus excluded areas Traffic and commuting patterns Expected growth (including extent, pattern and rate of growth) Meteorology (weather/transport patterns) Geography/topography (mountain ranges or other air basin boundaries) Jurisdictional boundaries (e.g., counties, air districts, Reservations, etc.) Level of control of emissions sources

Draft Timeline for Designations Process Milestone 1997 PM2.5 NAAQS Date 2006 PM2.5 NAAQS Date State and Tribal recommendations due Feb. 2004 Dec. 18, 2007 EPA Response June 2004 Summer 2008? States Comment Aug/Sept. 2004 ??? Final Designations Dec. 2004 by or before Dec. 18, 2009? Effective date of final designations April 2005 90 days after publication in FR