From: Roger Turner

To: Hall, Kristin

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Date: Tuesday, April 26, 2016 9:22:41 AM

Kristen:

Thank you.  I appreciate it.

Roger Turner

From: Hall, Kristin [mailto:Hall.Kristin@epa.gov]

Sent: Tuesday, April 26, 2016 10:21 AM

To: Roger Turner <rturner@sbtribes.com>

Cc: Suzuki, Debra <Suzuki.Debra@epa.gov>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Dear Roger,

Thank you for your response.  Based on your message, I understand that you do not wish to consult

on this action.  I also understand that you intend to comment on the EPA’s proposed rulemaking

when it is published.  I’ll be sure to notify you when the comment period opens – and I’ll send you a

link to the Federal Register notice at that time.

Thank you again for your interest and concern. 

Sincerely,

Kristin Hall

Air Planning Unit

EPA Region 10

Seattle, WA 98101

206-553-6357

From: Roger Turner [mailto:rturner@sbtribes.com]

Sent: Tuesday, April 26, 2016 8:28 AM

To: Hall, Kristin <Hall.Kristin@epa.gov>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Kristen Hall:

I think I am fine with the alternative ruling if R-10 is fine with it.  I appreciate you working with me on

it.  I do not believe we need consultation on this issue. 

We would like to comment on the Federal Reference comment period and I think that will suffice. 
With Idaho requesting and receiving  authority to reduce their match requirement for their Clean

Air Act grant, they have limited resources and limited enforcement capability....so alot slips through

the cracks.

Thanks again for your explanation and support.

Regards,

Roger Turner

From: Hall, Kristin [mailto:Hall.Kristin@epa.gov]

Sent: Monday, April 25, 2016 4:34 PM

To: Roger Turner <rturner@sbtribes.com>

Cc: Suzuki, Debra <Suzuki.Debra@epa.gov>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Dear Roger,

The short answer is that Idaho has limited the alternative to stationary sources only – it may only be

requested in the context of a stationary source permit to construct or operating permit application. 

The stationary source permit must contain appropriate monitoring, recordkeeping, and reporting

requirements.

But I sense that we should set up a phone call with you and others here to discuss all your questions

and concerns.  Please let me know what dates and times may work for you.

Thanks again, 

Kristin Hall

Air Planning Unit

EPA Region 10

Seattle, WA 98101

206-553-6357

From: Roger Turner [mailto:rturner@sbtribes.com]

Sent: Monday, April 25, 2016 2:18 PM

To: Hall, Kristin <Hall.Kristin@epa.gov>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Kristen Hall:

Perhaps you can help me a bit on this.
I understand that the Federal Standard for sulfur in #1 and #2 highway diesel is 15 ppm. While Nonroad is 500 ppm by weight.

Idaho is proposing the alternative, when sources are stack tested and shown to equal or that of the

low-sulfur fuel.  But there is no stack test methods cited, no parameters and no limit to the sulfur

content of the proposed alternative fuel. (The lack of parameters in testing was provided in the

letter to Idaho by Daniel Brown, and we are supportive of this position.)   Also it looks like a onetime stack test might give the source an exemption forever.  Since sulfur content of sources might

vary...so too should the frequency of stack testing to demonstrate equivalence.

Also the purpose of federal fuel standard, according to the web-site is to reduce sulfur emissions in

highway diesel, as well as other sources.   Since Idaho does not have funding to test highway diesel

fuel sources, or trucks, in a way that would demonstrate compliance, the proposed standard may

allow high sulfur fuels to be used on the highways.  One way to prohibit the highway diesel from

having high sulfur would be to limit Idaho’s alternative regulation to stationary sources. 

Unfortunately the present alternative proposed by Idaho includes highway diesel, as well as residual

fuel, which as pointed out above, seems un-enforceable. 

Could I have some feed-back from you on these issues?  I might be missing something. 

Thanks,

Roger Turner,

Interim Air Quality Manager

From: Hall, Kristin [mailto:Hall.Kristin@epa.gov]

Sent: Monday, April 25, 2016 1:28 PM

To: Roger Turner <rturner@sbtribes.com>

Cc: Suzuki, Debra <Suzuki.Debra@epa.gov>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Dear Roger,

As promised, I am sending additional information to you about the Idaho sulfur in fuels rule revision. 

Because you have expressed interest in this rule in the past, we are reaching out to discuss the rule

changes with you.

As you know, many years ago Idaho started a process to revise the state’s sulfur in fuels rule.  The

EPA reviewed the proposed changes and identified problems with the rule as drafted.  On July 1,

2009, the EPA submitted an official comment letter to Idaho stating the EPA’s concerns.  Please see

attached 2009 comment letter.

Over the course of several years, Idaho DEQ worked to revise the sulfur in fuels rule to address the
EPA’s concerns.  Idaho made changes to specify that a source seeking a permit to construct or

operate must demonstrate compliance with the sulfur in fuels limits, or in the alternative, through

control measures or other means, demonstrate that emissions would be equal to or less that

emissions from burning compliant fuels.  The demonstration must be based on a one-hour

averaging period, to protect the one-hour sulfur dioxide air quality standard. 

Idaho ultimately revised the state sulfur in fuels rule at IDAPA 58.01.01.725.05 (state effective

4/11/15), and submitted the rule change to the EPA for approval on May 19, 2015.  Please see the

attached 2015 Idaho cover letter, per your request.  Also at your request, I am sending a link to a

similar Oregon provision at OAR 340-228-0130. 

At this time, we are reviewing the Idaho submitted rule revisions, and intend to propose action

through a Federal Register notice – in the future.  Please let us know if you have further questions

or would like more information.

Thank you again for your interest. 

Sincerely,

Kristin Hall

Air Planning Unit

EPA Region 10

Seattle, WA 98101

206-553-6357

From: Hall, Kristin

Sent: Friday, April 22, 2016 8:26 AM

To: 'Roger Turner' <rturner@sbtribes.com>

Subject: RE: Idaho-SIP-Sulfur in Fuel alternative Compliance

Thank you for your interest, Roger.  I am out of the office today, but I will gather up the information

you have requested and get it to you Monday.  I am also happy to speak with you on the phone.

Thank you again, Kristin

Kristin Hall

Air Planning Unit

EPA Region 10

Seattle, WA 98101

206-553-6357

From: Roger Turner [mailto:rturner@sbtribes.com]

Sent: Friday, April 22, 2016 8:20 AM

To: Hall, Kristin <Hall.Kristin@epa.gov>

Cc: AirQuality <AirQuality@sbtribes.com>

Subject: Idaho-SIP-Sulfur in Fuel alternative Compliance
Kristin Hall:

Could we have a little more information on the proposed Sulfur Content in Fuel alternative that is

under consideration in Idaho’s Air Quality Regulations and SIP.  If you could provide me with Idaho’s

letter to Region 10 on this matter, it would be appreciated. Has other States employed this same

alternative in Region 10?

Will there be a Federal Register notice?

We are interested in the alternative standard Idaho is proposing for Sulfur content in Fuel.

Thanks for your consideration in this request,

Regards,

Roger Turner

Interim Air Quality Manager

Shoshone-Bannock Tribes

P.O. Box 306

Fort Hall, ID 83203

rturner@sbtribes.com