Notification of the Federal Land Manager

Role of Federal Land Managers (FLM)

If LDEQ receives a Nonattainment New Source Review (NNSR) or Prevention of Significant Deterioration (PSD) permit application for a source that “may affect” a Class I area, the FLM charged with direct responsibility for managing these lands will be notified [1].  This notification will be made to the following staff contacts at the FLM agencies who handle air quality concerns:

Breton National Wildlife Refuge
Caney Creek Wilderness Area
  Ms. Catherine Collins
U.S. Fish and Wildlife Service, Air & Water Resources
7333 West Jefferson Avenue, Suite 375
Lakewood, Colorado  80235-2034
P: (303) 914-3807

Ms. Judith Logan
Western Zone Air Resource Specialist, R8
U.S. Department of Agriculture Forest Service
P.O. Box 1270
Hot Springs, Arkansas  71902
P: 501-321-5341

The FLM is responsible for evaluating a source’s projected impact on Air Quality Related Values (AQRVs) (e.g., visibility, sulfur and nitrogen deposition, any special considerations concerning sensitive resources, etc.) and recommending that LDEQ either approve or disapprove the source’s permit application based on its anticipated impacts.  The FLM also may suggests changes to or conditions for a permit.  However, LDEQ makes the final decision on permit issuance.  The FLM also advises reviewing agencies and permit applicants about other FLM concerns, identifies AQRVs and assessment parameters for permit applicants, and makes ambient monitoring recommendations.

The meaning of the term “may affect” is interpreted by EPA policy to include all major sources or major modifications which propose to locate within 100 kilometers (km) of a Class I area.  However, if a major source proposing to locate at a distance greater than 100 km is of such size that LDEQ or the FLM is concerned about its potential impact on relevant AQRVs, LDEQ can ask the applicant to perform an analysis of the source’s potential impacts on such values.  This is because certain meteorological conditions, or the quantity or type of air emissions from large, but distant sources, may cause adverse impacts.  In order to determine whether a source located further than 100 km from a Class I area may affect that area, LDEQ uses the Q/d approach described below.

When to Notify the FLM – the Q/d Approach
The FLM has developed internal screening criteria using a “Q/d” approach.  Q/d refers to the ratio of the sum of annual emissions (in tons per year, based on 24-hour maximum allowable emissions) of PM10, SO2, NOx, and H2SO4 from the source to the distance (in kilometers) to the nearest boundary of the Class I area.

Q/d = PM10 (NEI) + SO2 (NEI) + NOx (NEI) + H2SO4 (NEI) / Class I km
PM10 (NEI) = net emissions increase of PM10
SO2 (NEI) = net emissions increase of SO2
NOx (NEI) = net emissions increase of NOx [2]
H2SO4 (NEI) = net emissions increase of H2SO4
Class I km = distance to nearest Class I area (in kilometers)

Except that:

  • If the net emissions increase of any pollutant is negative, enter “0”; and
  • If the project did not trigger a netting analysis, use the project increase. [3]  In this case, the value will be less than the pollutant’s significance level.

If Q/d ≥ 10, What Should an Applicant Do?

If Q/d ≥ 10 [4], the applicant should contact the Federal Land Manager as early in the process as possible.  This may be done prior to submittal of an application to LDEQ.

Once an application is submitted, LDEQ will formally notify the FLM in accordance with LAC 33:III.504.E.1 and/or LAC 33:III.509.P.1.

Class I Modeling
There are two general approaches to visibility analyses, depending upon whether a source is within 50 km of the Class I area or farther away.  In the “near field,” coherent plume impacts are assessed using either the VISCREEN model or the more rigorous PLUVUE II model.  For sources greater than 50 km from a Class I area, the CALPUFF model should be used.  Recommendations for evaluating visibility impacts, visibility assessment procedures, and natural visibility conditions and analysis methods are addressed in Section 3.3 of the October 2010 FLAG Phase I Report.

Modeling protocols should be approved by the FLM and the Air Permits Division prior to initiating the actual modeling runs.

On the Web
Breton National Wildlife Refuge 

Breton 300 km Radius
Caney Creek 300 km Radius 

[1] For Clean Air Act designated Class I area purposes, the official Federal Land Manager is the “Secretary of the Department with authority over such lands” (40 CFR 51.166(b)(24)).  The FLM role for the Department of the Interior has been delegated to the Assistant Secretary for Fish and Wildlife and Parks, and the day-to-day technical work is carried out by the U.S. Fish and Wildlife Service’s Branch of Air Quality and the National Park Service’s Air Resources Division.  The FLM role for the Department of Agriculture has been delegated to the Forest Service and re-delegated to the Regional Forester or individual Forest Supervisor, with technical staff assigned within those organizations.  Through this document, the term “FLM” refers jointly to both the designated official and the technical staff directly involved with Clean Air Act duties on behalf of designated Class I areas.

[2] If both NNSR and PSD review are required, select the higher of the two “net emissions increase” values.  The net emissions increase for NNSR and PSD purposes may be different due to differing contemporaneous periods.

[3] See §504.A.3 (NNSR) and §509.A.4 (PSD).

[4] The applicant should not round (e.g., if Q/d = 9.9, notification of the FLM is not required).