'-

STATE OF IDAHO 

DEPARTMENT OF 

ENVIRONMENTAL QUALITY 

~ ~rc~n1!1"" JJN 1 B 1010 D 

OFFICE OF THE EXECUTIVE 

1410 North Hilton· Boise, Idaho 83706· (208) 373·0502 C.L. "Butch" Otter, Governor 

Toni Hardesty,· Director 

June 25, 2010 EPA -IfIO-~ :Z<) tl· (;'(,<7 

r 6t?/-I -rZl(J-oA«---2_Qo-(Jl.;l'fDennis J. McLerran, Regional Administrator 

USEPA Region 10, MS RA-140 

1200 Sixth Avenue 

Seattle, WA 98101 

Dear Mr. McLerran: 

On behalf of the State of Idaho, the Department of Environmental Quality hereby submits 

the following: 

• Interstate Transport State Implementation Plan 

• Updated Certification ofIdaho State Implementation Plan Adequacy Regarding 

Clean Air Act Sections 11 O(a)(l) and (2) 

• News Release 

• Notice of Public Comment 

The Interstate Transport Plan does not revise Idaho's existing State Implementation Plan 

(SIP) rather it describes how Idaho's existing SIP meets the requirements of Section 

110(a)(2)(D)(i) of the Clean Air Act with regard to the 1997 annual PM2.5, the 200624-

hour PM2.5, and the 1997 and 2008 8-hour ozone National Ambient Air Quality 

Standards. Section 110(a)(2)(D)(i) provides that each state must submit a SIP that 

contains adequate provisions: 

"(i) prohibiting ... any source or other type of emissions activity within the 

State from emitting any air pollutant in amounts which will 

(I) contribute significantly to nonattaimnent in, or interfere with maintenance 

by, any other State with respect to such national primary or secondary ambient 

air quality standard, or 

(II) interfere with measures required to be included in the applicable 

implementation plan for any other State under part C to prevent significant 

deterioration of air quality or to protect visibility," 

P,/IlIad on Rocyclod {'aper 

Dennis J. McLerran, Regional Administrator 

USEPA 

June 22, 20 I 0 

Page 2 

The attached document explains how Idaho's current SIP and statutes meet the 

requirements of Section 110(a)(2)(D)(i) with the exception of the requirement to 

protect visibility. That demonstration will be included in Idaho's Regional Haze 

SIP currently under Federal Land Manager review. 

The Updated Certification updates the "Certification of Idaho State Implementation Plan 

Adequacy Regarding Clean Air Act Sections JJO(a)(J) and (2)" that Idaho submitted on 

September 15, 2008 with regard to Sections 1l0(a)(2)(D) and 1l0(a)(2)(G) and the 1997 

armual PM2.5, the 2006 24-hour PM2.5, and the 1997 and 2008 8-hour ozone National 

Ambient Air Quality Standards. 

A public comment period for the Plan and Updated Certification was held May 

11,2006 through June 10, 2010. No comments were received during the public 

comment period. No public hearing was held, because Idaho meets the 

requirements of Sections 110(a)(I) and (2) without revising the State 

Implementation Plan. (See William T. Harnett's Memorandum "Guidance on SIP 

Elements Required Under Sections 110(a)(I) and (2) for the 2006 24-hour Fine 

Particle (PM2.5) National Ambient Air Quality Standards (NAAQS)"). 

As requested, an original and two copies ofthese documents are being provided to 

you and your staff. Electronic copies will be provided upon request. If you or 

your staff have any questions concerning Idaho's submittal, please contact Sue 

Richards, Air Quality Analyst, DEQ Air Quality Division, at (208) 373-0586. For 

any questions of a legal nature, please contact Lisa Carlson, Deputy Attorney 

General at (208) 373-0494. 

Sincerely, 

Toni Hardesty 

Director 

cc: Martin Bauer, Administrator, Air Quality Division 

NOTICE OF 30-DAY PUBLIC COMMENT PERIOD AND HEARING 

REGARDING PROPOSAL ON INTERSTATE TRANSPORT 

PROPOSED ACTION: The Department of Environmental Quality (DEQ) is proposing 

to submit a State Implementation Plan (SIP) to the Environmental Protection Agency 

(EPA) demonstrating that Idaho's existing SIP provisions, rules, and emissions meet the 

requirements of Section II O(a)(2)(D)(i) ofthe Clean Air Act. Idaho is required to 

demonstrate that interstate transport of emissions from Idaho will not interfere with any 

other state efforts to: (l) attain or maintain the 1997 annual PM2.5, the 2006 24-hour 

PM2.5, and the 1997 and 2008 8-hour ozone National Ambient Air Quality Standards, (2) 

prevent significant deterioration of air quality, or (3) protect visibility. 

Idaho is also updating its Certification ofIdaho State Implementation Plan Adequacy 

Regarding Clean Air Action Sections IIO(a)(I) and (2). 

AVAILABILITY OF MATERIALS: The Interstate Transport SIP materials are 

available for public review on DEQ's Web site at http://www.deq.idaho.gov.Printed 

materials will be made available upon request at any of the regional offices in Coeur 

d' Alene, Lewiston, Boise, Twin Falls, Pocatello, and Idaho Falls. 

SUBMISSION OF WRITTEN COMMENTS-ASSISTANCE ON TECHNICAL 

OUESTIONS: Anyone may submit written comment regarding this proposal. To be 

most effective, comments should address air quality considerations and include support 

materials where available. Comments, requests, and questions regarding the public 

comment process should be directed to Faye Weber, Department of Environmental 

Quality, 1410 N. Hilton, Boise, ID 83706-1255, faye.weber@deq.idaho.gov, or (208) 373-

0440. Please reference "Interstate Transport" when sending comments or requesting 

information. 

For technical assistance on questions concerning tins project, please contact Sue Richards 

at (208) 373-0502 or Sue.Richards@deq.idaho.gov. 

All written comments conceruing this proposal must be directed to and received by the 

undersigned on or before 5:00, p.m., MST/MDT, June 10, 2010. 

DATED this 11th day of May, 2010. 

Department of Environmental Quality • May 11, 2010 • For Immediate Release 

NewsRelease 

ME D I A 

CONTACT 

• Sue Richards 

Air Quality Division 

DEQ State Office 

(208) 373-0502 

DEQ seeks comment on plan showing emissions 

from Idaho do not harm air quality in other states 

BOISE - The Idaho Department of 

Environmental Quality (DEQ) is seeking 

public comment on a plan demonstrating 

that emissions from Idaho are not 

adversely impacting air quality in other 

states. 

The plan, entitled Interstate 

Transport State Implementation Plan, 

shows that Idaho's existing air quality 

State Implementation Plan and rules 

prohibit emissions from Idaho sources 

from interfering with other states' efforts 

to meet air quality standards and protect 

visibilily. 

The plan is snbject to approval by the 

U.S. Environmental Protection Agency 

(EPA). 

The plan is available for review at 

DEQ's State Office, 1410 N. Hilton, 

Boise, regional offices in Boise, Coeur 

d' Alene, Idaho Falls, Lewiston, Pocatello 

and Twin Falls, and in PDF format on 

DEQ's Web site at www.deq.idaho.govl 

public/comment. cfm. 

For technical information on the plan, 

contact Sue Richards, DEQ Air Quality 

Division, at (208) 373-0502 or 

sue.richards@deq.idaho.gov . 

The deadline for commenting on the 

plan is 5 p.m. MST, Thursday, June 10, 

2010. 

Submit written comments 

electronically on DEQ's Web site or by 

mail or email to: 

Faye Weber 

Air Quality Division 

DEQ State Office 

l41ON. Hilton 

Boise, ill 83706 

Email: faye. weber@deq.idaho.gov 

End 

Department of Environmental Quality • May 11, 2010 • For Immediate Release 

NewsRelease 

ME D I A 

CONTACT 

• Sue Richards 

Air Quality Division 

DEQ State Office 

(208) 373-0502 

DEQ seeks comment on plan showing emissions 

from Idaho do not harm air quality in other states 

BOISE - The Idaho Department of 

Environmental Quality (DEQ) is seeking 

public comment on a plan demonstrating 

that emissions fi'om Idaho are not 

adversely impacting air qnality in other 

states. 

The plan, entitled Interstate 

Transport State Implementation Plan, 

shows that Idaho's existing ail' quality 

State Implementation Plan and rules 

prohibit emissions from Idaho sources 

from interfering with other states' efforts 

to mcct air quality standards and protect 

visibility. 

The plan is subject to approval by the 

U.S. Enviromnental Protection Agency 

(EPA). 

The plan is available for review at 

DEQ's State Office, 1410 N. Hilton, 

Boise, regional offices in Boise, Coeur 

d' Alene, Idaho Falls, Lewiston, Pocatel1o 

and Twin Fal1s, and in PDF format on 

DEQ's Web site at www.deq.idaho.govl 

public/comment.cfm. 

For technical information on the plan, 

contact Sue Richards, DEQ Air Quality 

Division, at (208) 373-0502 or 

sue.richards@deq.idaho.gov . 

The deadline for commenting on the 

plan is 5 p.m. MST, Thursday, June 10, 

2010. 

Submit written comments 

electronical1y on DEQ's Web site or by 

mail or email to: 

Faye Weber 

Air Quality Division 

DEQ State Office 

l4l0N.Hilton 

Boise, ID 83706 

Email: faye. weber@deq.idaho.gov 

End 

NOTICE OF 30-DAY PUBLIC COMMENT PERIOD AND HEARING 

REGARDING PROPOSAL ON INTERSTATE TRANSPORT 

PROPOSED ACTION: The Depmtment of Environmental Quality (DEQ) is proposing 

to submit a State Implementation Plan (SIP) to the Environmental Protection Agency 

(EPA) demonstrating that Idaho's existing SIP provisions, rules, and emissions meet the 

requirements of Section 110(a)(2)(D)(i) of the Clean Air Act. Idaho is required to 

demonstrate that interstate transport of emissions from Idaho will not interfere with any 

other state efforts to: (1) attain or maintain the 1997 mmual PM2.5, the 2006 24-hour 

PM2.5, and the 1997 and 2008 8-hour ozone National Ambient Air Quality Standards, (2) 

prevent significant deterioration of air quality, or (3) protect visibility. 

Idaho is also updating its Certification ofIdaho State Implementation Plan Adequacy 

Regarding Clean Air Action Sections Il0(a)(l) and (2). 

AVAILABILITY OF MATERIALS: The Interstate Transport SIP materials are 

available for public review on DEQ's Web site at !ill12:llwww.deq.idaho.gov.Printed 

materials will be made available upon request at any of the regional offices in Coeur 

d' Alene, Lewiston, Boise, Twin Falls, Pocatello, and Idaho Falls. 

SUBMISSION OF WRITTEN COMMENTS-ASSISTANCE ON TECHNICAL 

OUESTIONS: Anyone may submit written comment regarding this proposal. To be 

most effective, comments should address air quality considerations and include support 

materials where available. Comments, requests, and questions regarding the public 

comment process should be directed to Faye Weber, Department ofEnviromnental 

Quality, 14l0N. Hilton, Boise, ID 83706-1255, faye.weber@deq.idaho.gov,or(208)373-

0440. Please reference "Interstate Transport" when sending comments or requesting 

information. 

For technical assistance on questions concerning this project, please contact Sue Richards 

at (208) 373-0502 or Sue.Richm·ds@deq.idaho.gov. 

All written comments concerning this proposal must be directed to and received by the 

undersigned on or before 5:00, p.m., MST/MDT, .hme 10, 2010. 

DATED this 11th day of May, 2010. 

Updated Certification of Idaho State Implementation 

Plan Adequacy Regarding Clean Air Act Sections 

110(a)(1) and (2) 

On September 15, 2008, Idaho submitted "Certification ofIdaho State Implementation Plan 

Adequac;y"Regarding Clean Air Act Sections 110(a)(1) and (2)" to provide the Environmental 

Protection Agency (EPA) with certification that the Idaho State Implementation Plan (SIP) met 

the infrastructure requirements 0[7401 U.S.C. Section 2110(a)(1) and (2). This document 

updates that certification with regard to Sections 11 0(a)(2)(D) and 11 0(a)(2)(G) and the 1997 

annual PM2.5, the 2006 24-hour PM2.5, and the 1997 and 2008 8-hour ozone National Ambient 

Air Quality Standards. 

Clean Air Act Section 110(a)(2)(D) 

SIP Requirement: 

"(D) contain adequate provisions-

(i) prohibiting, cunsistent with the pruvisiuns uf this subchapter, any source or other type 

of emissions activity within the State from emitting any air pollutant in amounts which 

will-

(I) contribute significantly to nonattainment in, or interfere with maintenance by, 

any other State with respect to any such national primary or secondary ambient 

air quality standard, or 

(II) interfere with measures required to be included in the applicable 

implementation plan jor any other State under part C of this subchapter to 

prevent significant deterioration of air quality or to protect visibility, " 

Idaho Provisions: 

Included in this submittal is Idaho's Interstate Transport SIP that replaces the SIP submitted 

January 30, 2007. This SIP addresses Clean Air Act (CAA) Section 110(a)(2)(D)(i)(I) and pmt 

of CAA Section 11 0(a)(2)(D)(i)(II) with regard to prevention of significant deterioration. 

Idaho will submit the Regional Haze SIP sepm'ate1y due to differing notice and comment 

requirements. That submittal will address the remainder of CAA Section 11 0(a)(2)(D)(i)(II). 
Clean Air Act Section 110(a)(2)(G) 

SIP Requirement: 

"(G) provide for authority comparable to that in section 7603 of this title and adequate 

contingency plans to implement such authority; " 

Idaho Provisions: 

Emergency Order authority comparable to Section 303 of the Clean Air Act is located at Idaho 

Code Section 39-112. Idaho's Air Pollution Emergency Rules (Rules) (IDAP A 58.01.01.550 

through 562) meet the requirements ofCAA Section 110(a)(2)(G) as codified in 40 CPR 51 

Subpart H (Prevention of Air Pollution Emergency Episodes) and 40 CPR 51 Appendix L 

(Example Regulations for Prevention of Air Pollution Emergency Episodes). 

Idaho's Rules are modeled on the example regulations presented in 40 CPR 51 Appendix L. 

Idaho's Rules apply to the entire State regardless of regional classification (see 40 CPR 51.150) 

and meet all of the requirements listed in 40 CPR 51.152 (Contingency Plans). Table 1 lists the 

contingency plan requirements of 40 CPR 51.152 and the Idaho rule or code that meets it. 

Table 2 lists the air quality criteria defining emergency episode stages for ozone and PM25, POl' 

stages 2 through 4, the criteria for PM2.5 and PMIO is the same (PM2.5 is a subset ofPMlO). Ozone 

has 3 and PM2.5 has 7 levels (4 in Stage 1) of criteria that can trigger an episode stage and 

associated actions. Thus, Idaho meets the requirement (40 CPR 51.152(a)(I» for two or more 

stages of episode criteria for ozone and PM2.5. 

Idaho has no Priority I regions and is not required to establish a significant hann level in 

accordance with 40 CPR 51.151. Idaho's Rules are designed to prevent air quality anywhere in 

the State, without regard to regional classification, fi'om reaching significant harm levels. 
Table 1. Contingency Plan Crosswalk 

Plan Reqnirement Idaho Provision 

(a) Each contingency plan must-

(1) Specify two or more stages of episode criteria such as those set fOlih in IDAPA 58.01.01.556 (see Table 2) 

appendix L to this part, or their equivalent; 

(2) Provide for public announcement whenever any episode stage has been IDAPA 58.01.01.557 determined to exist; and 

(3) Specify adequate emission control actions to be taken at each episode 

stage. (Examples of emission control actions are set forth in appendix L.) 

IDAPA 58.01.01.561 

(b) Each contingency plan for a Priority I region must provide for the Idaho has no Priority I regions, 

following: however the following sections of the 

Rules meet these requirements: 

(1) Prompt acquisition of forecasts of atmospheric stagnation conditions 

IDAPA 58.01.01.552.01 and of updates of such forecasts as frequently as they are issued by the 

National Weather Service. 

IDAPA 58.01.01.121, the Inspection 

(2) Inspection of sources to ascertain compliance with applicable emission and Right of Entry authority located at 

control action requirements. Idaho Code Section 39-108, and the 

Emergency Order authority located at 

(3) Communications procedures for transmitting status reports and orders 

Idaho Code Section 39-112 

as to emission control actions to be taken during an episode stage, 

including procedures for contact with public officials, major emission 

557 

sources, public health, safety, and emergency agencies and news media. 

(c) Each plan for a Priority IA and II region must include a contingency IDAPA 58.01.01.552.01,121, tl,e 

plan that meets, as a minimum, the requirements of paragraphs (b )(1) and Inspection and Right of Enlly 

(b)(2) of this section. Areas classified Priority III do not need to develop authority located at Idaho Code 

episode plans. Section 39-108, and the Emergency 

Order authority located at Idaho Code 

Section 39-112 

(d) Notwithstanding the requirements of paragraphs (b) and (c) of this Not applicable 

section, the Administrator may, at his discretion-

(I) Exempt from the requirements of this section those pOliions of Priority 

I, lA, or II regions which have been designated as attainment 01' 

unclassifiable for national primary and secondary standards under section 

107 of the Act; 01' 

(2) Limit the requirements pertaining to emission control actions in 

Priority I regions to--

(i) Urbanized areas as identified in the most recent United States Census, 

and 

(ii) M~jor emitting facilities, as defined by section 169(1) ofU,e Act, 

outside the urbanized areas. 
Table 2. Idaho Air Quality Criteria and Associated Emergency Actions 

Stage Pollutant Criteria Actions 

I-Forecast Ozone NA There shall be no new ignition of open burning of any kind. 

and Caution 

PM25 80 ~m3 1-hr ave The Director may requjre, if practicable, or in an emergency situation. the cessation of any open 

PM2.5 50 ).tghn' 24-hr ave burning. 

PMlO 385 ~m3 1-hr ave 

PMlO 150 ~m' 24-hr ave 

2 - Alert Ozone 400 ).tglm' 1-hr ave There shall be no open burning of any kind. 

(0.2 ppm) 

The use ofbumers and incinerators for ihe disposal of any form of solid waste shall be prohibited. 

Persons operating fuel-burning equipment which requires boiler lancing or soot blowing shall perform 

PMlOIPM2.5 350 ).tglm' 24-hr ave such operations only between ihe hours of 12:00 pm (noon) and 4:00 p.m. 

Commercial, indUstrial and institutional facilities utilizing coal or residual fuel oil are required to 

switch to natural gas or distillate oil if available. 

3 - Warning Ozone 800 ~m' 1-hr ave There shall be no open burning of any kind 

(0.4 ppm) 

The use ofbumers and incinerators for ihe disposal of any form of solid waste or liquid waste shall be 

prohibited. 

PMj(,lPM" 420 ).lg/m' 24-hr ave 

Persons operating fuel-burning equipment which requires boiler lancing or soot blowing shall perfonn 

such operations only between ihe hours of 12:00 pm (noon) and 4:00 p.m 

Commercial, indUstrial and institutional facilities utilizing coal or residual fuel are required to switch 

completely to natural gas or distillate oil; or if these low snlfur fuels are not available, curtail the use 

of existing fuels to the extent possible wiihout causing injury to persons or damage to equipment. 

4- Emergency Ozone 1000 ).tglm' l-hr ave This will be called only with specific concurrence of Governor. 

(0.5 ppm) 

There shall be no open burning of any kind. 

PMlOIPM2.5 500 ).tglm' 24-hr ave The use of burners and incinerators for the disposal of any form of solid or liquid waste shall be 

.l'rohibited. --- _ ..• 
All places of employment described below shall immediately cease operations: 

i. All mining and quarrying operations; 

ii. All construction work except that which must proceed to avoid injury to persons; 

iii. All manufacturing establishments except those required to have in force an air pollution emergency 

plan; 

iv. All wholesale trade establishments, i.e. places of business primarily engaged in selling merchandise 

to retailers or industrial, commercial, institutional or professional users, or to other wholesalers, or 

acting as agents ill buying merchandise for or selling merchandise to such persons or companies 

except those engaged in the distribution of drngs, surgical supplies and food; 

v. All offices of local, county and State gO\remment including authorities, joint meetings, and other 

public bodies excepting such agencies which are determined by the chief administrative officer of 

local. county, or State government authorities, joint meetings and other public bodies to be vital for 

public safety and welfare and the enforcement of the provisions of this order; 

vi. All retail trade establishments except pharmacies, surgical supply distributors, and stores primarily 

engaged in the sale of food; 

vii Banks, credit agencies other than banks, securities and commodities brokers, dealers, exchanges 

and services; offices of insurance carriers, agents and brokers, real estate offices; 

viii. Wholesale and retail laundries, laundry services and cleaning and dyeing establishments; 

photographic studios; beauty shops, barber shops, shoe repair shops; 

ix. Advertising offices. consumer credit reporting, adjus1ment and collection agencies; duplicating, 

addressing, blueprinting; photocopying, mailing, mailing list and stenographic services; equipment 

rental services, commercial testing laboratories; 

x. Automobile repair, automobile services, garages except those located adjacent to state or interstate 

highways; 

xi. Establishments rendering amusement and recreational services including motion picture theaters; 

xu. Elementary and secondary schools, colleges, universities, professional schools, junior colleges, 

vocational schools, and public and private libraries. 

All commercial and manufacturing establishments not included in this order will institute such actions 

as will result in maximum reduction of the applicable air pollutant(s) from their operation by ceasing. 

curtailing, or postponing operations which emit the applicable air pollutants to the extent possible 

'Without causing injury to persons or damage to equipment. These actions include limiting boiler 

lancing or soot blowing operations for fuel burning equipment to betvveen the hours of 12:00 pm 

(noon) and 4:00 p.m. 

When the emergency episode is declared for carbon monoxide, the use of motor vehicles is prohibited 

except in emergencies or '\Vith the approval of local or state police or the Department.