Clean Air Act: Important issues and considerations during COVID-19
COVID-19 Considerations • Statements by the EPA and the DEQ • Preparing your facility for compliance • Documentation • Redundancy planning • Impacts to DEQ staffing • Impacts to State and DEQ budgets
Diesel, Indirect Sources, Implementation of House Bill 2007
Indirect Source Rulemaking • What are indirect sources? • What is the concern? • EQC received a petition Dec. 20, 2019 • Elements of Proposed Rulemaking • EQC voted to deny the petition on March 18, 2020 • Recommended by the DEQ • Reasoning • What is the DEQ doing now? • Summary of HB2007
Regional Haze
Regional Haze Rule- Update • What is it? • Regulatory history • What is a Class I area? • What is the Rule’s mandate? • Planning periods • What are steps undertaken by Oregon? • How are Oregon facilities affected? • What’s a Four Factor Analysis • Next steps for the DEQ
Governor Brown’s Executive Order on Climate Change
Executive Order on Reducing Greenhouse Gases • Emergency Board funding • Why an Executive Order now? • What are the reduction goals? • Five things the Order mandates • Next steps for the DEQ • Is this affected by COVID-19? • What has the DEQ done to date?
A New Office of Greenhouse Gas Programs is Created
Cleaner Air Oregon, Hazardous Index Rulemaking; and more
Cleaner Air Oregon – Hazard Index Rulemaking • Adopted April 24, 2020 • What did SB1541 allow? • Who does this affect? • How many pollutants are changed? • Diesel Particulate Matter added • How does the rule work in practice?
Example pollutants subject to HI = 5: -DGME -Propionaldehyde Example pollutants subject to HI = 3: -Ammonia -Formaldehyde -Diesel Particulate Matter Risk Determination Ratio = -Only Existing Sources Affected -Only Top 3 Risk Action Levels
Cleaner Air Oregon – Lessons Learned • DEQ has been flexible and attentive to facility concerns • Status of call-in process • Lessons learned- • Target Organs • Data needs are greater than expected • Requirements for de minimis sources • Ambiguity around new or existing source status • Zoning • Updates to emissions inventories state-wide in 2021 • What’s coming?
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