regon 

Theodore R. Kulongoski, Governor 

December 22, 2010 

Dennis McLerran, Regional Administrator 

U.S. Environmental Protection Agency, Region 10 

1200 Sixth Avenue 

Seattle, WA 98101 

Department of Environmental Quality 

Headquarters 

~ llfITV-t['-~'J~~~,~~iX;;2~:~~~~ 

~ ~ ~-=----·········fI t:: (503) 229-5696 

II I ': FAX (503) 229-6124 

DEC 2 3 2010 ~'j' TTY (503) 229-6993 

OFFICE OF THE EXECUTIVE 

RE: Revision to the Oregon State Implementation Plan: Correction to the Infrastructure Rule Changes 

Dear Mr. McLerran: 

The Oregon Department of Environmental Quality inadvertently left out the report addressing the 

interstate transport of ozone and fine pa,ticuJate matter when we submitted the request for approval of 

revisions to the Oregon State Implementation Plan (SIP) fi'om the Office of Air, Waste, and Toxics, State 

and Tribal Air Programs Unit ofthe U.S. EPA, Region 10 on June 23,2010. 

The Environmental Quality Commission adopted the "Oregon SIP Infrastructure for Addressing the 

Interstate Transport of Ozone and Fine Particulate Matter" as part of the revisions to the SIP under OAR 

340-200-0040 on April 30, 20 I O. DEQ submits this correction to EPA as part of the SIP and pursuant to 

40 CFR 51.104. 

I certify that public notices that included the "Oregon SIP Infrastructure for Addressing the Interstate 

Transport of Ozone and Fine Particulate Matter" report were published in newspapers of general 

circulation on November 17,2009, and in the Secretary of State's Oregon Bulletin on December 1,2009. 

The notices included a statement that adoption of the rules would revise the SIP. I further celtify that a 

public hearing was held on December 18, 2009 in Oregon. 

Thank you for your assistance with this correction to Oregon's infrastructure rule changes SIP. We have 

attached the interstate transport report and the revised SIP submittal documents. The staff contact for this 

correction is Carrie Capp, Air Quality Planning, at 503-229-5035, and Margaret Oliphant, SIP 

Coordinator, at (503) 229-5687. 

;;12 incere , 

··-u~L:. -------. 

Dick Pedersen, 

Director 

cc w/attachments: 

cc w/o attachments: 

Donna Deneen, EPA, Region 10 (3 complete sets plus 2 additional copies of 

revised rules, Attachment 3) 

Margaret Oliphant, DEQ Air Quality SIP Coordinator 

Andrew Ginsburg, DEQ Air Quality Administrator 

Paul Koprowski, EPA Oregon Operations office 
-
Attachments: 

Attachment 1: Evidence that the state has adopted the revision 

1.1 Staff Report, Agenda Item L of the April 28-30, 2010 EQC Meeting 

Also see Certificate and Order for Filing Permanent Administrative Rules in 

Attachment 4.2 

Attachment 2: Evidenced that the State has the necessary legal authority 

2.1 See Attachment 1.1 "Commission Authority" (page 2 of Staff Report, Agenda 

Item L, April 28-30, 2010 EQC Meeting) 

Attachment 3: Provisions Submitted for Approval, Effective May 21, 2010 _____ - , 

3.1 Redline/Strikeout Version of adopted, amend~rro:repealed SIP rules 

General Air Pollution proceduresznd Denruons: OAR 340-200-: 0020, 0025, '--;r6 W-t 

0040. , , 0""'-" 

Ambient Air Quality Standa~a a PSD Increments: OAR 340-202-: 0060, £l..~'l:..t.c, 

, 0090,0130. /. l "", 

Designation of Air Qy,trflty Areas: OAR 340-204-: 0010,0030. . ,J1))( 

Airpollut~'onEl ergencies: OAR 340-206-: 0010, 0030. ~e 'iJ"'" 

3.2 Adopted an mended SIP rules submitted to Secretary of State ~:cj1 

3.3 O.regon?· Infrastructure for Addressing the Interstate TranspOli of Ozone an.5!.-t/a.-;' 

Fme>li)-articulate Matter v \r-.... IU) 

",,/ ,., Attachment 4: Evidence that the State followed the Administrative Procedures Act 

----------------;4-:-1--Public-notice-in-tire-Secretmy-of-State'-s-0regon-Bulletin-Becemher-1-;-200~--------

4.2 Certificate and Order for Filing Permanent Administrative Rules, filed 

and effective May 21, 2010 

Attachment 5: Evidence of adequate public notice 

5.1 Affidavit of Publication: The Oregonian, Notice of November 17,2009 

publication 

Attachment 6: Certification of public hearing 

6.1 See paragraph three of cover letter and Attachment 7.1 

Attachment 7: Compilation of Public Comments and Department's Response ---------------

- . Tr --preSidingDffTcii'sRep()rtIorRu.lerrlakiilg-Reaiing--()-riDeceinber n,-:W09,-dateo 

April 29, 2010 

7.2 Summary of Public Comments and Agency Responses, dated December 31,2009 
/ 
x 1 

x 1.1 

x 2 

x 2.1 

x 3 

x 

x 

3.1 

x 

x 

X 3.2 

X 3.3 

X 4 

X 4.1 

X 4.2 

--------

X 5 

X 5.1 

X 6 

X 6.1 

X 7 

X 7.1 

X 7.2 

Evidence the State has Adopted the Revision 

Staff Report, Agenda Item L of the April 28-30, 2010 EQC Meeting 

See also Certificate and Order for Filing Permanent Administrative Rules in Attachment 4.2 

Evidence that the State has the Necessary legal Authority 

See Attachment 1.1 "Commission Authority" (page 2 of Staff Report, Agenda Item L, April 28-

30, 2010 EQC Meeting) 

Provisions Submitted for Approval, Effective May 21, 2010 

Redline/Strikeout Version of adopted, amended and SIP rules 

General Air Pollution Procedures and no-tin·i(tin 

Ambient Air Quality Standa 

AaOp]~eo and amended SIP rules submitted to Secretary of State 

SIP Infrastructure for Addressing the Interstate Transport of Ozone and Fine 

Evidence that the State followed the Administrative Procedures Act 

Public notice in the Secretary of State's Oregon Bulletin December 1,2009 

Certificate and Order for Filing Permanent Administrative Rules, filed and effective May 21, 

2010 

Evidence of Adequate Public Notice 

Affidavit of Publication: The Oregonian, Notice of November 17,2009 publication 

Certification of Public Hearing 

See paragraph three of cover letter and Attachment 7.1 

Compilation of Public Comments and Department's Response 

Presiding Officer's Report for Rulemaking Hearing on December 22, 2009, dated April 29, 2010 

Summary of Public Comments and Agency Responses, dated December 31,2009 
/ 
Attachment 3 

/",.. .. 1 

, ... , .. // .. --

Provisions Submitted for Approval, Effective M;,9--y"21, 2010 . / 

3.1 RedJine/strikeout version of adopted, ame~ed and repealed SIP rules. 

General Air Pollution Procedures a~15efinitions: OAR 340-200-: 0020,0025, 0040. 

Ambient Air Quality stani:ardS icI PSD Increments: OAR 340-202-: 0060,0090,0130. 

Designation of Air Quality eas: OAR 340-204-: 0010,0030. 

Air Pollution Emergenci : OAR 340-206-: 0010,0030. . 

3.2 Adopted and amfed SIP rules submitted to Secretary of Stare. ' 

3.3 Oregon SIP Inffastructure for Addressing the Interstate Transport of Ozone and Fine 

Particulate Matter / ' 

/ 

,/ 

Attachment 3.3, page 1 

Oregon SIP Infrastructure for 

Addressing the Interstate Transport of 

Ozone and Fine Particulate Matter 

Clean Air Act Section 11 0(a)(2)(D) 

Oregon Department of Environmental Quality 

November 5,.2009 
Attachment 3.3, page 2 

Contents 

Addressing Interstate Pollutant Impacts under the Clean Air Act.. .............................................. 3 

1. Significant Contribution to NMOS Violations ............................................................................ 5 

2. Interfere with Maintenance Requirements ................................................................................ 13 

3. Prevention of Significant Deterioration Requirement ..................................... : ........................ 17 

4. Protect Visibility Requirement .................................................................................................... 18 

Contact: 

Carrie Capp 

Air Quality Division 

(503) 229-5035 

2 
Attachment 3.3, page 3 

Addressing Interstate Pollutant Impacts under the 

Clean Air Act 

Overview 

Some amount orair pollution transport occurs routinely across all state borders and across all regions 

of the country. TIus document discusses Oregon's ability to address interstate air pollution transport 

as it relates to four key aspects of the Clean Air Act; compliance wjth federal air quality health 

standards for PM2.S and ozone, maintenance with federal air quality health standards for PM2.S and 

ozone, prevention of significant deterioration, and the protection of wilderness areas and national 

parks from air pollution that causes "haze" and can degrade visibility. Based on the information 

summarized in the sections that follow, DEQ concludes that particulate and ozone precursor 

emissions from Oregon sources do not significantly contribute to violations of national ambient air 

quality standards in other states, or interfere with other states efforts to meet air quality standards, 

prevent significant air quality degradation, or protect visibility. In developing this submittal DEQ 

consulted with EPA staff and air quality agencies in Washington, California, Nevada and Idaho. 

DEQ's conclusions are based on its understanding of air pollution problems in adjacent states, and 

the emission sources, meteorology (weather patterns), and topographic features (mountain ranges, 

-----ete-;-)-that-influenee-air-E}llality-13f0S1sHls-in-thss@-8t:atss'.--. ----------------------

DEQ will collaborate with Washington, Idaho, Nevada, California and other state air agencies 

whenever necessary to evaluate case-specific air quality problems that may involve regional transpOli 

of air pollution. DEQ's Section 110 infrastructure SIP provides the framework and legal mechanism 

for DEQ to act as needed to reduce any Oregon emissions found to significantly contribute to air 

quality problems in other states. Two recent examples ofDEQ's ability and willingness to address 

problems involving interstate transport are the Portland-Vancouver ozone attainment and 

maintenance plans, and Oregon's regional haze plan. The cities of Portland, Oregon and Vancouver, 

Washington share a common air shed. In the mid 1990s and again in 2007 DEQ collaborated with 

the Southwest Clean Air Agency (i.e. the air agency with jurisdiction over Vancouver) to develop bistate ozone attainment and maintenance plans. These plans included emission reduction strategies 

----n=-=e--=-eaea to attaIn anamaintain compliancevlTtfh-feaetal ozone stanclarcls:-IIr2008":~09-DE(tworkeQ-­

with the States of Washington, Idaho and California, as well as Federal Land Managers in developing 

Oregon's Regional Haze plan. Under that plan DEQ adopted several emission reduction strategies, 

including emission control requirements for the PGE Boardman coal-fired power plant, to reduce the 

interstate transport of haze forming emissions. 

The map below (Figure 1) illustrates the significant distances and mountain ranges that in many areas 

separate Oregon from communities in Washington, California, Idaho, and Nevada, and can help limit 

the long range transport of air pollution. DEQ's consultation with air agencies in adjacent states 

suggests that high PM2.S levels in their respective communities are driven largely by local pollution 

sources during events of air stagnation. Local air stagnation events would generally preclude 

interstate air pollution transport as a significant contributor to high PM2.S levels jeopardizing 

NAAQS compliance. Conceptually, regional emissions from all Pacific Northwest states could play 

some small role in regional background ozone levels depending on the location and circumstances; 

3 
Attachment 3.3, page 4 

however, based on the discussion presented in this document DEQ concludes that Oregon does not 

significantly contribute to ozone problems in other states. If any future violations of ozone standards 

occur, Oregon would work with other air agencies and EPA as necessary to evaluate the role of 

interstate air pollution transport. Regarding regional haze pollution, DEQ will continue to work with 

other states, federal land managers, and others on interstate transport issues for haze pollution 

through its on-going state Regional Haze planning process. 

Figure 1: Map of Oregon and major mountain ranges 

Section llO(a)(2)(D)(i) of the Clean Air Act 

The state of Oregon developed this SIP revision to meet requirements w1der Section 11 O( a )(2)(D )(i) 

of the Clean Air Act. In 2006 and 2007 respectively, EPA promulgated revised primary and 

secondary National Ambient Air Quality Standards (NAAQS) for fine partiCulate (PM2.5) and 

ground level ozone (03). When EPA adopts a new or revised NAAQS, each state must ensure that its 

SIP is adequate to implement, maintain, and enforce the NAAQS. Among other things, the SIP must 

meet the interstate transport requirements of Section 11 0(a)(2)(D)(i) of the Act. 

4 
Attachment 3.3, page 5 

Section 11 0(a)(2)(D)(i) requires each state to submit a SIP that ensures a state can and will prohibit 

any emissions source or other type of emissions activity within the state from emitting air pollutants 

in amounts that will: . 

(1) Contribute significantly to nonattainment or interfere with maintenance of a primary or 

secondary NAAQS in another state, or 

(II) Interfere with measures in another state's SIP to prevent significant deterioration of air 

quality or protect visibility. 

EPA issued guidance to the states on August 15,2006, and additional guidance on September 25, 

2009 regarding Section 11O(a)(2)(D)(i) requirements for the 8-hour 0 3 and PM2.5 NAAQS. The state 

of Oregon relied on both guidances in developing this document. The EPA guidance divides Section 

110(a)(2)(D) requirements into the following four categories: 

• "Significant Contribution" requirement. 

• "Interfere with Maintenance" requirement. 

• "Prevention of Significant Deterioration" requirement. 

• "Protect Visibility" requirement. 

Each of these categories is discussed below. 

1. Significant Contribution to NAAQS Violations: Section 

110(a)(2)(O){I) 

The Oregon State Implementation Plan (40 CFR 52 Subpart MM) provides the mechanism required 

under the Clean Air Act to prohibit as necessary any emissions source or type of emissions activity 

within the state from emitting air pollutants in amounts that will contribute significantly to 

non attainment in another st~te with respect to the PM2.5 and 8-hour ozone (03) NAAQS. DEQ can 

and would take action as necessary to assist states in preventing or correcting any violation of federal 

____ airgu'!liJyJl~altl1J3ti:lly:ia~ds._ ... . ... ___ _____________ _ 

Location of Nonattailmlent Areas in Neighboring States and General Topography: 

For PM2.5, the closest nonattainment areas in neighboring states are the Tacoma area (Pierce 

County) in Washington; the Chico area (portions of Butte County) in California, and the Cache 

Valley area in Southeast Idaho (portions of Cache County, Utah and Franklin County, Idaho). For 

Ozone, cunently all areas in Washington, Idaho and northern California are designated as 

attainment/unclassifiable by EPA. See Figures 2 and 3 for EPA maps of cunently designated ozone 

and PM2.5 nonattainment areas. 

The area of highest Oregon emission densities (Portland Metro area) is separated from ozone and 

PM2.5 nonattainment areas in Washington, Idaho and California by significant distances and major 

mountain ranges up to approximately 7,000 feet (see Fig 1). The one exception is the PortlandVancouver metro area, which shares a common air shed between Oregon and Washington. As 

5 
Attachment 3.3, page 6 

discussed below, both Portland and Vancouver are in attainment with both the PM2.5 and 8-hour 

ozone standards. The Portland-Vancouver air shed is managed for ozone under the bi-state PortlandVancouver ozone maintenance plan. Distances from the Portland-Vancouver Metro areas to 

neighboring nonattainment areas are significant: Portland to Tacoma, WA - approx. 120 miles, 

Portland to Franklin County, Idaho - approx. 590 miles, Portland to Seattle, WA - approx. 145 miles, 

Portland to central California nonattainmentareas (e.g. Sacramento, San Francisco Bay Area, Los 

Angeles range from approximately 500 to 800 miles. 

Fi ure 2: EPA Ma of desi nated PM2.5 nonattainment areas Re ions 9 and 10 (2009) 

6 

Attachment 3.3, page 8 

Figure 4: Example wind rose for winter PM2.5 season. 

Winter Win9 ~.~s(;}s: p~q~rflber ~ ~J~!1L!~fY. 

In the Pacific Northwest, exceedances ofthe 8-hr ozone standard occur in the summer months. In 

Oregon, prevailing winds are predominantly from the north to northwest and would preclude any 

significant influence from Oregon on Washington ozone nonattainment areas (see Figure 5). 

Prevailing summer winds could result in some interstate transport of ozone forming emissions from 

Oregon to western Idaho, Nevada and northern California. However as discussed in the sections 

below, significant distances and topography (such as major mountain ranges that separate Oregon 

from California, Idaho and Nevada) would likely minimize the significance of these impacts on other 

states. For example, the largest major urban center in Oregon (the greater Portland area) is 

approximately 400 to 700 miles away from urban areas in western Idaho, Nevada, and northern 

California, and is separated by at least one major mountain range (the Cascades). DEQ has consulted 

with air agencies in each state and concludes that Oregon emissions do not playa significant role in 

high ozone levels in others states. Oregon's infrastructure SIP provides DEQ the ability to work with 

EPA and others states as needed to address regional ozone problems in the future should they arise. 

8 
Attachment 3.3, page 9 

Figure 5: Example wind rose for summer ozone season. 

Summer Wind Roses: Ju'ly • August 

Monitoring: Figures 6 and 7 show the distribution of2008 federal reference PM2.5 and ozone 

monitoring in Oregon, Washington, Idaho, Nevada and Califomia. In the sections below, DEQ 

describes ozone and PM2.5 attainment problems areas in these other states, as well as likely 

contributing sources based on conversations with other state air agencies. Monitoring data in all states 

is reviewed routinely by air agencies and EPA. High PM2.5 or ozone levels that threaten the NAAQS 

---- -----are investigatedas neede-cf to-IdentTtycontributin-gsources, inchiding-ml,Y potentlalroleofillterstatetransport. The state Section 110 infrastructure SIP elements ensure the capacity for each state to 

coordinate with each other and with EPA to characterize air quality data, i<;lentifY contributing 

emission sources (both local and regional) and evaluate other factors that may jeopardize NAAQS 

compliance. 

9 
Attachment 3.3, page 10 

AirData 

Shaded counties hove monitors 

Monitor Location: [J PM2.5 (150) 

Source: US EPA Office of Air and Radiation, AQS Database Wednesday, Oelober 28, 2009 

AirData 

Shaded counties have monitors 

Monitor Locotion: V 03 (233) 

Thursday, October ~ 2009 

10 
Attachment 3.3, page 11 

Modeling: As part of EPA's initial development of the federal interstate air pollution rule, known as 

CAIR (Clean Air Interstate Rule) EPA modeled air transport to detennine any significant 

contributions to nonattainment. EPA concluded that because of geography, meteorology, and 

topography it was reasonable to exclude the Western u.s from the CAIR rule. Based on EPA's 

conclusions, and the information summarized in this document, DEQ believes that additional 

modeling of interstate PM2.5 or ozone transport is not needed at this time to support DEQ' s 

conclusions. 

Summary of Consultation with Washington, Idaho, Nevada, and California; 

In preparing this document, DEQ consulted with air agency staff in Washington, Idaho, Nevada and 

California to detennine the ozone and PM2.5 nonattainment status of communities, and get a sense of 

what the local air agencies believe are the likely causes of air quality concerns or violations ofPM2.5 

and ozone NAAQS. The following sections summarize DEQ's discussion with each state air agency 

and DEQ's review of EPA teclmical support documentation for recent non attainment area 

designations. 

WASHINGTON 

Washington PM2.5 Nonattainment 

In December 2007, the State of Washington recommended that a pOliion of Pierce County (Tacoma 

area) be designated non attainment for the 2006 24-hr PM2.5 standard. EPA has conculTed with the 

states recommended non attainment area designation and boundary. Pursuant to section 107 (d) of the 

Clean Air Act, EPA must designate as nonattainment those areas that violate the NAAQS and those 

nearby areas that contribute to violations. The state of Washington and EPA evaluated nearby 

counties in the Seattle, Tacoma and Olympia areas for their contributions to fine particulate levels in 

the Tacoma area; including an assessment of pollutant emissions, air quality data, population density 

and degree of urbanization, traffic, growth, meteorology (including back trajectories), and 

topography. Based on this analysis, EPA has designated the Wapato Hills-Puyallup River Area (a 

portion of Pierce County) as nonattainment for PM2.5. 

Significant emission sources in the Wapato Hills-Puyallup River area contributing to wintertime 

-- -PM2.5-violationsjnclude-outdooLopelLburning(24%),-mobile-sources-(27-%),-fireplace-and--------

woodstove emissions (39%), and miscellaneous other sources (10%). Air emissions from the state of 

Or~gon were not identified by Washington or EPA as a contributor to violations of the PM2.5 

standard. 

Portland-Vancouver Interstate Ozone Area 

The Portland-Vancouver Interstate Ozone Area comprises Portland, Oregon and Vancouver, 

Washington. The area was a maintenance area for the I-hour ozone standard, and has been meeting 

the 8-hour ozone NAAQS since the standard was promulgated in 1997. In 2007, the Oregon 

Department of Environmental Quality (OR DEQ) and Southwest Clean Air Agency (SWCAA, 

Vancouver, W A) worked together on a modeling analysis and updated ozone maintenance plan that 

demonstrates that the Portland-Vancouver area will continue to attain the 03 NAAQS through 2015. 

This bi-state plan will ensure Oregon and Washington emission sources do not interfere with 

11 
Attachment 3.3, page 12 

maintenance of the ozone NAAQS. EPA is currently reviewing the Portland-Vancouver ozone 

maintenance plan. 

IDAHO 

Idaho PM2.5 Nonattainment 

EP A has designated portions of the Cache Valley area in Southeast Idaho as nonattainment for 

PM2.5. The nonattainment area boundary encompasses portions of Cache County, Utah and Franklin 

County, Idaho. In establishing 'the nonattainment boundary the State of Idaho and EPA evaluated 

information on significant contributing emissions sources, including factors such as an assessment of 

pollutant emissions, air quality data, population density and degree of urbanization, traffic, growth, 

meteorology and topography. ' 

Franklin County is essentially topographically separate from the rest of the state as it is surrounded 

by mountain ranges. EPA concluded that it is very unlikely that surrounding counties contribute to 

violations of PM2.5 standards. EPA further concludes, along with both the states of Idaho and Utah, 

that exceedance levels ofPM2.5 are produced by air inversions and confined to the lower Valley 

areas. Thus no areas other than the partial county areas in Cache and Franklin Counties are 

appropriate for consideration within the nonattainment area. EPA's conclusion indicates that air 

emissions from Oregon do not contribute to PM2.5 non attainment. Oregon DEQ supports this 

conclusion. 

Ozone Nonattainment: 

As Shown in Figure 3, all counties in Idaho are in compliance with federal ozone standards. 

CALIFORNIA 

Northern PM2.5 Nonattainment: 

The Chico area (lower elevation portions of Butte County) is the most northerly area in California 

currently designated non attainment for PM2.5. The state of California and EPA conducted an 

analysis to identify emission sources contributing to violations of the PM2.5 NAAQS and to 

designate an appropriate non attainment area boundary. This analysis included an evaluation of 

emissions data (primary and secondary PM2.5 such as S02, NOx, VOC and NH3), as well as air 

quality data, population density and degree of urbanization, traffic, groWth, meteorology and 

topography. An analysis of air pollution rose indicates that elevated levels of 24-hr PM2.5 

concentrations for the Chico area occurs primarily when the wind is from the 'south, but occasionally 

when the wind is from the north. The pollutant rose analysis also indicates that elevated 24-hr PM2.5 

values occur during the cool season, during periods of low wind speeds. These meteorological 

conditions would preclude sig~ificant air pollution transport from Oregon. EPA concludes that the 

majority of contributing PM2.5 emissions is from local residential wood smoke, with some PM2.5 

contribution from surrounding county sources. Air emissions from the state of Oregon were not 

identified by California or EPA as a contributor to violations of the PM2.5 standard. 

12 
Attachment 3.3, page 13 

Ozone Nonattainment: 

Mid-state ozone nonattainment areas include metro areas such as Sacramento and the San Francisco 

Bay Area. Distances from the Portland-Vancouver Metro area to mid-state California are on the order 

of 500 miles. More southerly portions of California such as Los Angeles are designated as 

nonattainment for ozone as well and are on the order of 500- 800 miles from Oregon. Oregon DEQ 

and California air agency staff do not believe that Oregon contributes to ozone NAAQS violations in 

California given the long distances involved, topographic features and weather patterns that would 

limit any significant ozone transport from Oregon. 

NEVADA 

PM2.S Nonattainment 

The entire state of Nevada was classified attainrnentlunclassifiable under the 1997 PM2.5 NAAQS. 

EPA is in agreement with Nevada's recommendation that the entire state be designated 

attainmentlunclassifiable based on the 2006 PM2.S NAAQS. 

Nevada Ozone 

The Las Vegas area was designated as an ozone nonattainment area based on the 1997 ozone 

NAAQS. The rest of the state was designated as unclassifiable/attainment. Nevada has recommended 

the same designations for the 2008 Ozone NAAQS as for the 1997 standards. The air agency for 

Clark County (Southern Nevada) has conducted detailed studies, emissions inventories, 

and modeling work to address ozone issues. Study results indicate that Clark County is often 

impacted by transpOli of ozone and ozone precursors primarily from Southern and Central 

Califomia; and under certain scenarios, by transport from areas outside of the southwestem region 

(including Southern Califomia and Arizona). Nevada has no data suggesting impacts on ozone 

concentrations in Southem Nevada caused by transport from the state of Oregon. 

Conclusion: 

Based on the infonnation described above, DEQ concludes that emissions from air pollution sources 

in Oregon do not significantly contribute to nonattainment of the 8-hourozone or PM2.S NAAQS in 

_____ otherillates-'-___________________________________________ ------- --------------------

2. Interfere with Maintenance Requirements: 

Section 11 0(a)(2)(0)(1) 

The Oregon State Implementation Plan (40 CFR 52 Subpart MM) provides the mechanism required 

under the Clean Air Act to prohibit as necessary any emissions source or type of emissions activity 

within the state from emitting air pollutants in amounts that will interfere with the maintenance of 

PM2.

5 and 8-hour 03 NAAQS in another state. 

As described earlier in this document, factors such as major mountain ranges, significant transport 

distances, and the nature of high ozone or PM2.5 events (such as seasonal wind flows and winter air 

stagnation events) make it unlikely that emissions transpOli from Oregon would interfere with the 

13 
Attachment 3.3, page 14 

maintenance of ozone or PM2.S NAAQS in other states. DEQ's Section 110 infrastructure SIP 

ensures that Oregon DEQ has the ability to paliicipate as needed in future studies on regional air 

pollution issues, or collaborate with other states if air quality concerns are identified that require a 

case-specific evaluation of interstate transport. Oregon's infrastructure SIP also ensures the legal 

mechanism for DEQ to take action as needed to reduce emissions to help attain or maintain 

compliance with federal NAAQS. 

Topography/Meteorology/Climatology: The same topography and meteorology described in Section 

1 above applies when evaluating maintenance ofNAAQS in adjacent states. High PM2.5 

concentrations in adjacent states typically occur under winter conditions when air speeds are low 

andlor localized air inversions occur. Figure 4 above illustrates typical seasonal wind patterns during 

the winter when PM2.5 levels are highest. Wind direction is typically variable with the majority of 

wind speeds less than 8 miles per hour, and a significant portion of low winds less than 5 miles per 

hour. These low wind speeds and air stagnation conditions do not lend them to long distance air 

pollution transport. 

Occasional high 8-hr ozone levels occur in the summer months. Prevailing winds in Oregon are 

predominantly from the north to northwest and would preclude any significant influence from Oregon 

on Washington ozone nonattainment areas (see Figure 5). Prevailing summer winds could 

theoretically result in some interstate transport of ozone forming emissions from Oregon to western 

Idaho, Nevada and northern California. However as discussed in the sections above, significant 

distances and topography (such as major mountain ranges that separate Oregon form California, 

Idaho and Nevada) would likely minimize the significance ofthese impacts on other states. For 

eXalnple, the largest major urban center in Oregon (the greater Portland area) is approximately 400 to 

700 miles away from urban areas in western Idaho, Nevada, and northern California, and is separated 

by at least one major mountain range (the Cascades). As shown in Figures 6 and 7 and discussed in 

the next section, EPA's monitoring data for 2006-2008 shows that both PM2.5 and ozone design 

values in all counties adjacent to Oregon are below the PM2.5 and ozone NAAQS. 

Monitoring: 

EP A monitoring data for 2006-2008 shows that both PM2.5 and ozone design values in all counties 

immediately adjacent to Oregon are below the PM2.5 and ozone NAAQS. 

Three northern California Counties (not adjacent to Oregon) have PM2.5 or ozone design values 

above the NAAQS but have not yet been designated nonattainment by EPA. Plumas and Shasta 

counties in northem California have 24-lu' PM2.5 design values above the NAAQS. Tehmna County 

in northern California has al1 8-hr ozone design value above the ozone NAAQS. Consultation with 

air agency staff in these counties suggests the primary cause of PM2.5 exceedances are local 

wintertime woodstove smoke, summertime road dust and wild fire impacts, and possibly some local 

industry. In Plumas Co, high ozone values are typically experienced when transport winds are from 

the southwest, not from the north. Plumas County is downwind from the Sacramento metro area, and 

southerly winds are thought to produce the highest ozone readings. 

Similarly, in Tehama Co., measurement of ozone transport suggests the main area of influence to be 

the greater San Francisco Bay Area. Ozone transport monitoring in Tehmna Co. is located at the 

2000-foot level, and suggests that predominant transport winds move pollution through the San 

Francisco bay/delta areas; blow along the foothills and up to the monitor. 

14 
Attachment 3.3, page 15 

No other attainment counties in Washington, Nevada, Idaho, or northern California have design 

values violating the PM2.5 or ozone NAAQS. Monitoring data and conversations with state and 

county air agency staff (summarized here and below) supports DEQ's conclusion that Oregon 

emission sources are not interfering with NAAQS maintenance in adjacent states. 

Summary of Consultation with Washington, Idaho, Nevada, and California. 

As in Section 1 above, DEQ consulted with air agency staff in Washington, Idaho, Nevada and 

California to deternline the ozone and PM2.5 status of communities, and get a sense of what the local 

air agencies believe are the likely causes of air quality concerns for maintaining compliance with 

PM2.5 and ozone NAAQS. The following sections summarize DEQ's discussion with each state air 

agency and DEQ's review of EPA monitoring data for Washington, Idaho, Nevada, and California. 

WASHINGTON 

PM2.5 Maintenance: As shown in Figure 2, with the exception of the Tacoma area all other areas in 

Washington are designated as Unclassifiable/Attainment at this time.! If any Washington PM2.5 

non attainment areas are identified in the future ODEQ will work with the Washington Department of 

Ecology or Southwest Clean Air Agency as needed to evaluate any contribution from interstate air 

pollution transport. DEQ's infrastructure SIP ensures the ability to collaborate with other air agencies 

on transport analysis when and if needed. 

Ozone Maintenance: As shown in Figure 3, all counties in Washington are currently in attainment 

willi ozone stanCiarCis. Tlie city or-Seattle currently meets the federal ozone NAAQS. Each summer, 

Seattle experiences elevated ozone levels that typically occur under northerly winds (i.e. winds 

blowing from north to south). This strongly suggests that Oregon emissions sources (approximately 

175 miles to the south of Seattle) have no significant affect on Seattle's summer peak ozone events. If 

future violations of ozone standards occur in Seattle, or other areas of Washington, DEQ will 

collaborate with Washington air agencies as needed to evaluate any contribution from regional 

interstate air pollution transport. 

IDAHO 

PM2.5 Maintenance: In the Northern part of the state the community of Pinehurst experiences high 

. .. __ lev~IQ._QfJ)M2~)_and JI~ ~t:lteis -'Y'QIkingJ¥iili EPA Q_nstmh;giesJQpr~yenttheare-,iJrom_reaching __ 

non attainment status. The area also has PMI0 issues with the biggest contributing source being wood 

stoves. The elevated levels occur during periods of air stagnation so it is very unlikely other areas in 

Idaho or interstate transport are contributing to the increased levels of particulate. 

Ozone Maintenance: While cUlTently in attainment status, Boise is seeing monitored concentrations 

of ozone at levels that are occasionally close to the NAAQS. Idaho DEQ will be closely monitoring 

these levels and will likely investigate contributing sources. There is no information at this time to 

suggest any significant contribution from Oregon emission sources. DEQ will collaborate with Idaho 

DEQ as needed to evaluate any role of intrastate transport. 

1 40 CFR Ch. 1 Part 81 Subpart C Section 107, Attainment Status Designations, 7-1-08 Edition 

15 
Attachment 3.3, page 16 

CALIFORNIA 

PM2.S Maintenance: Modoc, Siskiyou, Plumas, and Shasta counties in northern California 

experience evaluated PM2.S levels, primarily in the winter due to air stagnations and local sources 

such as woodstoves, but occasionally in the summer due to wildfire smoke. Occasional exceedances 

ofthe PM2.5 NAAQS are measured, but no areas have been designated as non attainment for PM2.S. 

Wood burning devices are a common residential heat source in these areas, and NAAQS exceedances 

are thought to be a result of both woodstove smoke and coinciding inversions. The Siskiyou 

mountain range (approx 6,000 to 7,000 feet) separates western Oregon from California and would 

help limit the transport of air pollution into California. It is unlikely that Oregon air pollution sources 

would significantly contribute to NAAQS exceedances in northern California given the local 

topography, significant distances involved (on the order of SO to 1 OO'miles or more), and the air 

stagnation meteorology that helps produce high winter time PM2.S levels. 

Ozone Maintenance: As shown in Figure 3, both the North Coast Air Basin (Del Norte, Humboldt. 

Mendicino, Sonoma (part) and Trinity Counties) and the Northeast Plateau Air Basin (Lassen, 

Modoc, and Siskiyou Counties) are designated as Unclassifiable/Attainment for the 2006 Ozone 

NAAQS. Collectively, these two basins constitute the northern portion of California where the 

interstate transport of Oregon ozone forming emissions could potentially occur based on seasonal 

wind patterns. While northern California has not experienced any ozone violations, there have been a 

few days of elevated levels (summertime events). Califoinia air agencies may further investigate 

ozone levels and transport in these areas, and Oregon DEQ can collaborate as needed in such studies; 

however, DEQ's consultation with air agency staff in these counties suggest that high ozone values in 

these areas are influenced primarily by the Sacramento or San Francisco areas under northerly winds. 

There is no evidence to suggest any significant contribution from Oregon. 

NEVADA 

PM2.S Maintenance: 

As shown in Figure 2, the entire state of Nevada has been classified attainment/unclassifiable under 

PM2.S NAAQS. 

Ozone Maintenance: 

As shown in Figure 3, with the exception of the Las Vegas area in southern Nevada, the entire state 

has been designated by EPA as attainmentlunclassifiable with the ozone NAAQS. 

Clean Air Interstate Rule (CAIR) 

As described in the overview, based on available information Oregon DEQ concludes that particulate 

and ozone precursor emissions from Oregon sources do not significantly contribute to violations of 

national ambient air quality standards in other states, or interfere with other states efforts to meet air 

quality standards. In 2004, EPA reached this same conclusion as part of their initial development of 

the federal interstate air pollution rule, known as CAIR. Clean Air Interstate Rule (CAIR) 

16 
Attachment 3.3, page 17 

At the time the CAIR rule (then titled "Rule to Reduce Interstate Transport of Fine Particulate Matter 

and Ozone (Interstate Air Quality Rule).,,2 was initially proposed, EPA conducted an analysis to 

identify states that were contributing significantly to nonattainment ofPM2.5 and 0 3 in adjacent 

states. The Preamble to the proposed federal Interstate Air Quality Rule stated the following with 

regard to Oregon: 

In analyzing significant contributions to nonattainment; we determined it was reasonable to exclude 

the Western US, including the States of Washington, Idaho, Oregon, California, Nevada, Utah and 

Arizona from further analysis due to geography, meteorology, and topography. Based on these 

factors, we concluded that the PM2.5 and 8-hour ozone nonattainmentproblems are not likely to be 

affected significantly by pollution transported across these States' boundaries. Therefore, for the 

purpose of assessing State's contributions to nonattainment in other States, we have only analyzed the 

nonattainment counties located in the rest of the US 3 

Conclusion: 

Based on the information described above, DEQ concludes that emissions from air pollution sources 

in Oregon do not interfere with the maintenance of the 8-hour ozone or PM2.5 NAAQS in other 

states. 

3. Prevention of Significant Deterioration Requirement: 

Section-11~Ota~)(z-)·tBl(+)'--------

The state of Oregon concludes that the Oregon State Implementation Plan (40 CFR 52 SUbpart MM) 

provides the mechanism required under the· Clean Air Act to prohibit as necessary any emissions 

source or type of emissions activity within the state from emitting air pollutants in amounts that will 

interfere with another state's SIP measures for preventing significant deterioration of air quality or 

protecting visibility. 

Oregon has no EPA designated 8-hour 03 nonattainment areas, and has two designated PM2.5 

nonattainment areas. For most of the state, Oregon will permit new major industrial sources through 

___ ~ JheJ>reyentiou of Significant Deterioratio!1~{£.SJ2tpJ12gram fOL1hes.e p<21lulal11s. DEQ's N.ew$our~e~~~~ 

Review (NSR) rules ensure that the maintenance ofNAAQS in neighboring states is not jeopardized 

by new or expanding industrial sources. Specifically, all new industrial sources and major 

modifications to existing industrial sources in attainment areas are subject to DEQ PSD rules 

requiring pre-construction review, air quality analysis, the application of any required emission 

control technology, and air pennitting. All new sources and major modifications in nonattainment 

areas are subj ect to the nonattainment New Source Review provisions of these rules, including 

LAER, offsets, and netting air quality benefit. DEQ is on schedule to update the rules to address 

PM2.5. Oregon's PSD program also includes procedures to address Phase-II requirements of the 

Final Rule to implement the 8-Hour Ozone National Ambient Air Quality Standard.4 

2 Proposed rule at 69 FR 4566, January 30, 2004. 

369 FR at 4581, January 30, 2004. 

470 FR 71612, November 29,2005. 

17 
Attachment 3.3, page 18 

Non-interference and visibility measures and protection of Class-I area visibility in neighboring states 

is achieved through the visibility and Air Quality Related Value requirements of the PSD rules. 

Adjacent states and Federal Land Managers are notified of any proposed new or expanding major 

industrial source that may have the potential for significant impacts in their states or regions and 

provided the opportunity to review and comment on ,air quality analyses. In addition to reviewing any 

DEQ analysis, Federal Land Managers may also submit visibility impact analysis to DEQ for 

consideration during the industrial source permitting process. 

New Nonattainment Areas for PM2,5 

The communities of Klamath Falls and Oakridge, Oregon have recently been designated 

non attainment for PM2.5 by EPA. Oregon DEQ and the Lane Regional Air Pollution Agency 

(LRAPA) will develop PM2.5 New Source Review (NSR) procedures as part of each community's 

PM2.5 attainment plan. These plans, together with supporting rules, will be adopted as an amendment 

to the state of Oregon SIP. 

4. Protect Visibility Requirement: Section 

11 O(a){2)(D){i){lI) , 

EPA's Regional Haze regulations required that states submit Regional Haze plans to EPA by 

December 17, 2007. 5 Most states have been delayed in SUbmitting their regional haze plans (SIP 

revisions), primarily due to the complexity of conducting Best Available Retrofit Technology 

(BART) analysis for selected older industrial sources. Oregon submitted its regional haze plan to 

EP A for review and approval July 14, 2009. Oregon DEQ will continue to collaborate with the states 

of California, Washington and Idaho, EPA, 'Federal Land'Managers, and Inany others to develop 

regional strategies for reducing haze across the Pacific Northwest. Oregon's Regional Haze Plan was 

deemed complete by EPA in September 2009, and is now being reviewed for approval. The plan 

includes emission reduction requirements for several older major industrial facilities, including 

stringent pollution control requirements for Portland General Electric's coal-fired power plant near 

Boardman. The new requirements will result in significant visibility improvements and reduced 

pollution for the region's Class I wilderness areas and national parks as well as the Columbia River 

Gorge National Scenic Area. 

-###-

. 564 FR 3517, July 1,1999. 

18