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APPLYING THE AOH REPORT IN MONTANA

This presentation discusses the regulatory approach in Montana based on the AOH Report and explores the factors causing haze in Glacier National Park. It also analyzes the contributions of sulfates and nitrates from various sources and their impact on neighboring states. The conclusion emphasizes the need for defensible control strategies and further modeling to determine the next steps.

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APPLYING THE AOH REPORT IN MONTANA

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

  2. AOH Report: Almost Over Bob’s Mom’s Head

  3. BOB’S MOM

  4. REGULATORY APPROACHOVERVIEW • Authority to Regulate (have). • Resources to Negotiate (some). • Source by Source BART. • Non-BART source analysis. • BART burden on source – DEQ to review and issue BART Determination. • TSD modeling to drive controls.

  5. REGULATORY APPROACH(continued) • “You Go First” Approach. • Colorado begins domino effect. • SIP due 2008 – ten year plan – 2018 – five year RFP analysis – 2013. • Public meetings only when draft plan developed. • BART and Smoke Management key. • AoH products to facilitate discussions – but not to make determinations.

  6. What’s Causing Haze in GNP? • 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.

  7. Who’s Doing it? SULFATES • 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?

  8. NITRATES • Nitrates are mostly from Mobile Sources and are coming from outside the state. • Question: Best way to explain “other”?

  9. MT CONTRIBUTION OUTSIDE STATE • Most contribution within state. • Outside state, greatest impact to N. Absaroka, WY and Teddy Roosevelt NP, ND • Similar distribution for Nitrates

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

  11. SIP Planning Timeline

  12. 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).

  13. END OF SLIDES

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