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APPLYING THE AOH REPORT IN MONTANA

APPLYING THE AOH REPORT IN MONTANA. Bob Habeck June 2005 WRAP AOH Workgroup Meeting Seattle, WA. AOH Report:. A lmost O ver Bob’s Mom’s H ead. BOB’S MOM. REGULATORY APPROACH OVERVIEW. Authority to Regulate (have). Resources to Negotiate (some). Source by Source BART.

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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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