1 STATE OF NEW MEXICO BEFORE THE ENVIRONMENTAL IMPROVEMENT BOARD IN THE MATTER OF PROPOSED REVISIONS TO THE STATE IMPLEMENTATION PLAN FOR THE SAN JUAN GENERATING STATION BEST AVAILABLE RETROFIT TECHNOLOGY DETERMINATION No. EIB 13
- 02(R)

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NEW MEXICO ENVIRONMENT DEPARTMENT’S NOTICE OF INTENT TO PRESENT TECHNICAL TESTIMONY

Pursuant to 20.1.302.A NMAC, the New Mexico Environment Department (NMED) hereby submits its Notice of Intent to Present Technical Testimony in this proceeding. 1. The person for whom the witnesses will testify. The New Mexico Environment Department. 2. The name an d qualifications of each technical witness. Mr. Ted Schooley

. Ted Schooley has served as the Permitting Programs Manager of the Air Quality Bureau within NMED since May, 2013. He began with the Bureau in May of 2001 as the Minor Source Manager, and later served as the Technical Services Manager of the Permitting Section in the Bureau. Mr. Schooley holds a Bachelor of Science degree in Mechanical Engineering from Louisiana State University, New Orleans, as well as a Bachelor of Science in Math and Physics f rom the University of Texas at El Paso. He is a registered Professional Engineer in mechanical engineering in the State of Louisiana. His resume is attached as Exhibit 10a. Ms. Elizabeth Bisbey

- Kue h n . Elizabeth Bisbey

- Kuehn is currently the Acting Technical Services Manager for the Air Quality Bureau within NMED . She has served in the Bureau since February of 2005 as a Permit Specialist

– a role she continues to perform in addition to her2 managerial re sponsibilities. She also served as Acting Minor Source Section Manager from May through October of 2012. Ms. Bisbey

- Kuehn holds a Bachelor of Science degree in Environmental Studies from the University of Iowa. Her resume is attached as Exhibit 11a.
Dr. Gi

- Dong Kim

. Gi

- Dong Kim is a Modeling Specialist in the Modeling Unit of the NMED’s Air Quality Bureau’s Planning and Policy Section, where he has worked for eleven years. Dr. Kim holds a Ph.D. and a Master of Science Degree in Environmental Engineerin g from the University of Tennessee. His responsibilities with the Bureau include the review and performance of computer

- based dispersion modeling in support of permitting, enforcement and regulation development actions. Dr. Kim has performed approximately 154 modeling analyses for the Bureau. His resume is attached as E xhibit 12a. Ms. Rita Bates . Rita Bates is the Section Chief of the Planning Section of NMED’s Air Quality Bureau. She has more than 20 years of experience in the environmental field, incl uding fourteen years with NMED. In addition to her work for the Air Quality Bureau, Ms. Bates has worked in industry as an environmental coordinator and in environmental consulting as a project manager. Ms. Bates holds a B.S. in Biology from Humboldt Sta te University. Her resume is attached as Exhibit 13. 3. A copy of the direct testimony of each witness in narrative form. Copies of the direct testimony of Ted Schooley, Elizabeth Bisbey

- Kuehn, and Gi

- Dong Kim are attached as Exhibits 10, 11, and 12, resp ectively. NMED does not intend to present direct testimony by Rita Bates, but may present her as a rebuttal witness, and will make her available to assist in answering questions that may go beyond the expertise of the direct witnesses.3 In addition, NMED intends to present non

- technical testimony by Mr. Ryan Flynn, Secretary

- Designate of the Department. Mr. Flynn will testify briefly in support of the proposed regulatory changes, based on policy reasons.
4 . Text of any recommended modifications to the pr oposed regulatory change. NMED does not have any recommended modifications to the proposed SIP revisions. NMED supports the adoption of the revisions to Chapter 10 and Appendix D of New Mexico’s Regional Haze SIP as contained in the public review versions of those documents that were filed with the Board on June 27, 2013.
5. List and a ttach all exhibits to be offered at the hearing . NMED offers the following exhibits, which are attached hereto:
NMED Ex. 1 Clean Air Act §§ 169A and 169B
NMED Ex. 2 40 C.F.R . § 51.308
NMED Ex. 3 40 C.F.R. § 51.309
NMED Ex. 4 Appendix Y to 40 C.F.R. Part 51

– BART Guidelines
NMED Ex. 5 “Term Sheet” between U.S. EPA, NMED, and PNM
NMED Ex. 6 BART Analysis Addendum, PNM San Juan Generating Station, April 1, 2013
NMED Ex. 7 Affidavits of publication of public hearing notices
NMED Ex. 8 Public Comments Submitted by the U.S. Bureau of Land Management
NMED Ex. 9 Public Comments Submitted by the National Park Service
NMED Ex. 10 Testimony of Ted Schooley
NMED Ex. 10a Resume of Ted Schooley
NMED Ex. 11 Testimony of Elizabeth Bisbey

- Kuehn
NMED Ex. 11a Resume of Elizabeth Bisbey

- Kuehn