Working with Federal Land Managers to Evaluate Prevention of Significant Deterioration (PSD) Applications, A Moving Target, 1996 Environmental Conference Proceedings

Air permitting for new or modified sources requires a comprehensive evaluation of air quality impacts as defined by the Federal Prevention of Significant Deterioration (PSD) regulations (40 CFR 52.21). Facilities planning modifications which are subject to the PSD requirements must estimate impacts for comparison to ambient air quality standards and PSD increments. In addition, an estimate of impacts to air quality related values (AQRV), typically impacts to soils, vegetation, and visibility, is also required. As required by the Clean Air Act (as amended in 1977), the federal land managers are obligated to review the evaluations to AQRV impacts in Class I areas (primarily National Parks and Wilderness Areas). The permitting authority is obligated to consider comments from the federal land managers before issuing the PSD permit. Because of a lack of consistent methodologies, comments from the federal land managers can sometimes be inconsistent and pose problems to applicants attempting to evaluate impacts in a comprehensive and reasonable manner. This paper defines technical and procedural problems associated with a Class I AQRV analysis for impacts from the Weyerhaeuser North Bend Containerboard facility on the Kalmiopsis Wilderness Area on the Southern Oregon coast. Specific issues and analyses will be presented. The results show the impact of the lack of data in the wilderness areas and the lack of an agreed upon methodology with which to evaluate visibility impacts. Because of technical requirements that were not consistent, the state permitting authority was required to make a decision based on factors other than the technical merits of the situation.