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Treatment in the Same Manner As A State (TAS). An Example of Real World applications Forest County Potawatomi Community Natalene Cummings Air Program Director. Forest County Potawatomi Community Keepers of the Fire. FCPC sought CAA TAS to:.
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Treatment in the Same Manner As A State (TAS) An Example of Real World applications Forest County Potawatomi Community Natalene Cummings Air Program Director Forest County Potawatomi Community Keepers of the Fire
FCPC sought CAA TAS to: • Receive the reduced match requirement for grant funding – 45% 5% (CAA § 105) • Receive notification from state of any Title V permit applications AND have extra clout on comments submitted (CAA § 505(a)(2)) • Added CAA § 126 Interstate pollution abatement – because Laura said to Forest County Potawatomi Community Keepers of the Fire
How’s that working out for ya? • § 105 – reduced funding match • Moved from 103 project funding to 105 program following TAS approval • What can I say? Forest County Potawatomi Community Keepers of the Fire
How’s that working out for ya? • § 505 – Title V permit notification • receiving notices via snail mail, a week after 30 day comment period begins • 30 days is not enough time to review permit • Comments submitted too late in the game – not well received • Power is very limited compared to Class I permit review • Get training on permit review or hire consultant • Know your Title V sources • Research their 5 year renewal date • Get friendly with the state permit reviewers • Consider Class I redesignation Forest County Potawatomi Community Keepers of the Fire
How’s that working out for ya? • § 126 Interstate Pollution Abatement • Currently in attainment for NAAQS • Potential for ozone non-attainment looms Forest County Potawatomi Community Keepers of the Fire
What next? • § 110(a)(2)(D) - Adverse Impact of AQ on Downwind Lands • 107(d)(3) - opportunity to provide input/recommendations on NAAQS attainment designations Forest County Potawatomi Community Keepers of the Fire
Natalene Cummings Air Program Director Forest County Potawatomi Community natalene.cummings@fcpotawatomi-nsn.gov 715-478-7211 Forest County Potawatomi Community Keepers of the Fire