Minnesota Pollution Control Agency 

52OLafayetteRoad North I St.Paul,MN55155-4194 ) 651-296-6300 1 800-657-3864 / 651-282-5332 TTY / www.pca.state.rnn.us 

November 29, 2007 

Ms. Mary Gade (R-19J) 

Regional Administrator 

U.S. Environmental Protection Agency 

Region V 

77 West Jackson Boulevard 

Chicago, Illinois 60604 

RE: Minnesota's 1 10(a) State Implementation Plan Requirements 

Dear Ms. Gade: 

This letter is to certify that Minnesota's State Implementation Plan (SIP) currently meets-the 

infrastructure requirements of section 110(a)(l) and (2) of the Clean Air Act in regards to the 

eight hour ozone and particulate matter less than 2.5 microns in diameter (PM2.5) National 

Ambient Air Quality Standards (NAAQS) promulgated in 1997. 

The Minnesota Pollution Control Agency (MPCA) has, in prior submittals, documented its 

authority and ability to provide for the implementation, maintenance and enforcement of primary 

and secondary standards, as well as to adopt enforceable emission limitations and control 

measures to meet the primary and secondary standards, and to update both state rules and the SIP 

as necessary. 

The Minnesota statute that lays out the powers and duties of the MPCA (Minn. Stat. 5 116.07) 

states, 

"The agency shall also adopt standards of air quality, including maximum 

allowable standards of emission of air contaminants from motor vehicles[.]" 

It goes on to give the agency the authority to 

"[Aldopt, amend, and rescind rules and standards having the force of law relating 

to any purpose.. .for the prevention, abatement, or control of air pollution." 

This statute also gives the agency the authority to enforce any provisions of the chapter relating 

to air contamination, including entering into orders, schedules of compliance and stipulation 

agreements, requiring owners or operators of emission facilities to install and operate monitoring 

equipment, and conducting investigations. 

St.Paul 1 Brainerd I Detroit Lakes I Duluth I Mankato I Marshall 1 Rochester I Willmar IS0 YEARS 

&sTtL~Z~OD 
Ms. Mary Gade 

Page 2 

Minnesota's SIP-approved air quality rules implement these statutory authorities and broadly 

cover the criteria pollutants: "sulfur dioxide, particulate matter, nitrogen oxides, carbon 

monoxide, ozone, lead, and any other pollutants for which national ambient air quality standards 

have been established" and prohibit emissions that cause or contribute to a violation of any 

ambient air quality standard. Minnesota rules also provide for enforcement to ensure that air 

quality rules are followed. 

The MPCA operates an ambient pollutant monitoring network and compiles and reports that 

information to the U. S. Environmental Protection Agency (EPA). 

Minnesota's air quality rules also make any NAAQS an applicable requirement for stationary 

sources. Under Minnesota rules, these sources may be required to monitor their emissions and 

major sources may be required to perform modeling to show that emissions do not cause or 

contribution to a violation of ambient air quality standards. Stationary sources are also required 

to pay emission fees to cover the MPCA's air permitting program; chargeable pollutants include 

all pollutants for which a NAAQS has been promulgated. Minnesota operates a delegated 

Prevention of Significant Deterioration Program to meet the requirements of parts C and D of the 

Clean Air Act. 

Minn. R. ch. 7009 contains the provisions for determining air quality emergency episodes, and 

establishes episode levels. The MPCA will revise these levels for PM2.5 and ozone once EPA has 

determined the appropriate significant harm levels and revised 40 CFR 5 5 1.150. 

The MPCA recently submitted a 1 10(a)(2)(D) SIP revision to meet Minnesota's requirements to 

not cause or contribute to NAAQS non-attainment in any other state. The visibility SIP is 

forthcoming. 

Through our discussions with your office, we believe this letter meets our requirements as 

described in the Guidance of SIP Elements Required Under Sections 11 O(a)(l) and (2) for the 

1997 8-hour Ozone and PM2,5 National Ambient Air Quality Standards, issued on 

October 2,2007. Please contact Catherine Neuschler of our staff at 65 1-296-7774 if you have 

any questions regarding Minnesota's SIP. 

Sincerely, 

Brad Moore 

Commissioner 

CN: sth 

cc: Kathleen D' Agostino, EPA Region V (AR- 1 8 J)