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April, 1981 PSD Guidance Document 9.4







|       ADDRESS        |



Prepared by:

P.O. BOX 25287

APRIL 1981


Purpose Page 2
Summary of the Clean Air Act as Amended
(August 7, 1977)
Page 3
Summary of Requirements Applicable to Class I Areas Page 5
A. NPS Permit Notification List A 1-4
B. FWS Permit Notification List B 1-3


This document provides guidance to persons intending to submit a Prevention of Significant Deterioration (PSD) permit application for a Major Emitting Facility (MEF) that has the potential to impact a Class I area managed by the National Park Service (NPS). Much of the information needed by the NPS to adequately evaluate a permit application must be collected well before the permit is submitted. By following the guidance in this document, the applicant can prevent delays in the review process caused by an incomplete application. Also, under a cooperative agreement with the Fish and Wildlife Service (FWS), the NPS Air Quality Division is providing technical review of PSD permits that affect FWS Class I areas. Therefore, the guidance provided herein applies to the FWS Class I areas as well.



The Clean Air Act (CAA), as amended in August, 1977, is a unique tool for use in the preservation of air quality and sensitive resources in the National Park and Wildlife Refuges.

Sections 160-169 of the Act established a detailed policy and regulatory program to protect the quality of the air in regions of the United States in which the air is cleaner than required by the National Ambient Air Quality Standards (NAAQS) to protect public health and welfare. One of the purposes of the program of Prevention of Significant Deterioration (PSD) is "to preserve, protect, and enhance the air quality in national parks, national wilderness areas, national monuments, national seashores, and other areas of special national or regional natural, recreational, scenic, or historic value."

Under the PSD provisions, Congress established a land classification scheme for those areas of the country with air quality better than the NAAQS. Class I allows very little deterioration of air quality; Class II allows moderate deterioration; and Class III allow more deterioration; but n all cases, the pollution concentrations shall not violate any of the NAAQS. Congress designated certain existing areas as mandatory Class I which precludes redesignation to a less restrictive class, in order to acknowledge the value of maintaining these areas in relatively pristine condition. These mandatory Class I areas include: (1) international parks (2) national wilderness areas and national memorial parks in excess of 5,000 acres; and (3) national parks in excess of 6,000 acres existing as of August 7, 1977. The National Park System includes 48 mandatory Class I areas (see Appendix A) and The Fish and Wildlife Service manages 21 mandatory Class I areas (See Appendix B). All mandatory Class I areas with their respective Federal land Managers are given in the November 30, 1979, FEDERAL REGISTER.

Lands can be redesignated by the States and, in some cases, by Indian tribes, as explained in Section 164 of the Act. Congress also protected other nationally significant lands by originally designating them as Class II and restricting redesignation to Class I only. These areas include existing national monuments, national primitive areas, national preserves, national recreation areas, national wildlife refuges, national wild and scenic rivers, national lakeshores and seashores in excess of 10,000 acres, and newly established national parks or wilderness areas in excess of 10,000 acres. All other areas were initially classified as Class II, and can be redesignated as either Class I or Class III.

Section 164(d) required the FLM to review all national monuments, primitive areas, and national preserves and to recommend any appropriate areas for redesignation to Class I. The recommendations, with supporting analysis, were reported to the Congress and the affected States and Indian tribes, that were responsible for undertaking any redesignation. These recommendations may be found in the June 25, 1980, FEDERAL REGISTER.

Congress provided two methods for protecting air quality and resources sensitive to changes in air quality. Section 163 established maximum allowable increases in air quality over baseline concentrations of certain pollutants

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for each class. These maximum allowable increases, or increments, cannot be exceeded by new or modified existing sources of those pollutants unless the owner or operator demonstrates to the satisfaction of the FLM, and the FLM certifies that air quality related values (AQRVs) of Class I areas will not be adversely affected. Such new or modified existing sources (Major Emitting Facilities - MEFs) are required to submit a preconstruction permit application to the Environmental Protection Agency (EPA) or to a State if permitting authority has been delegated to the state by the EPA or through an approved State Implementation Plan (SIP). The FLM is notified by the EPA or by the State the receipt of a permit application and has an opportunity to comment on the application if the MEF is to be located near a mandatory Class I area or if the pollutants from the facility would potentially violate the increments or affect the air quality related values of Class I areas. For the analysis, complete PSD applications should be forwarded to the National Park Service Air Quality Division, and the NPS Regional Director and Area Superintendent or the Air Quality Specialist at FWS and the Refuge Manager if a National Refuge is involved. The appropriate addresses are given in Appendices A and B.

Congress also gave the FLM an affirmative responsibility to protect AQRVs in mandatory Class I areas. AQRVs are all those values possessed by an area that may be affected by changes in air quality, and include all those assets of an area whose visibility, significance, or integrity are dependent upon the air environment. These values include visibility, odor, flora, fauna, and geological resources; archeological, historical, and other cultural resources; and soils and water quality resources. In the permit review process, no permit shall be issued if the FLM can convince the permitting authorities that one or more AQRV will be adversely affected regardless of whether the PSD increments would be met. Conversely, if the major emitting facility can convince the permitting authority and the FLM that no damage to AQRVs will occur, the source may be allowed to exceed the Class I PSD increments.

Congress has determined that potential impacts on visibility in mandatory Class I areas are so serious that special provisions are necessary to protect this specific air quality related value. Under the requirements of Section 169A of the CAA, the EPA promulgated regulations (40 CFR 51 Subpart P) that require those States with mandatory Class I areas submit implementation plans that assure the prevention of future and the remedying of existing visibility impairment. Federal Land Managers have already determined that visibility is an important value in all 48 of the mandatory Class I areas managed by the National Park Service. A recommendation on the 21 mandatory areas managed by FWS has not as yet been made. In order to remedy existing visibility impairment, the states are to establish regulations requiring that major stationary sources that were in existence on August 7, 1977 (but that were not in excess of 15 years old on that date) be retrofitted with controls representing the best available retrofit technology if those sources pose a threat to visibility in a mandatory Class I area. Prevention of future impairment is to be accomplished under the new sources review process.

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All the requirements of Title 40 of the Code of Federal Regulations, Part 52, section 52.21 (40 CFR 52.21) are applicable. Those requirements that the National Park Service will especially be reviewing are discussed in this section.

Air Quality Review [40 CFR 52.21(k)]

The permit application must contain an air quality analysis that analyzes the effect of the MEF on the Class I increment. The applicant shall base the air quality review on approved models as specified in 40 CFR 52.21 (l) (Guideline on Air Quality Models). All assumptions for the analysis should be explicitly stated, and sufficient information on modelling input should be furnished so that the model analysis can be duplicated by the NPS. The model must make maximum use of meteorological data as specified in the referenced Guideline on Air Quality Models. If the analysis indicates violations of Class I increments, the application must attempt to prove that there would be no damage to AQRVs. The applicant may wish to contact the National Park Service Air Quality Division (P.O. Box 25287, Denver, CO 80225) before doing the air quality review to be sure that the model will adequately predict the impact on the Class I area.

Monitoring [40 CFR 52.21 (m)]

A complete permit application must contain preapplication air monitoring data. In general one year of data is required. The National Park Service Air Quality Division should be contacted to facilitate installation of monitoring equipment in NPS Class I areas. Initiation of air monitoring studies in the National Parks originates in this office which in turn seeks the cooperation of the appropriate NPS Regional Office and Park Superintendent. This office will also coordinate monitoring efforts with the appropriate FWS authorities, if applicable. Since there are monitoring programs underway in several parks, contacting the Air Quality Division can help avoid duplication of effort.

Source Information [40 CFR 52.21 (n)]

The application must show that all sources have applied BACT for each pollutant emitted. In general, the source parameter information required by the State or EPA will suffice for the NPS permit review. However, by consulting with the Air Quality Division as soon as results of the air quality impact assessment are available, possible delays after permit submittal can be avoided should the NPS require additional information.

Additional Impact Analyses [40 CFR 52.21 (o)]

Because the Federal Land Manager has an affirmative responsibility to protect air quality related values in Class I areas and to consider whether a proposed source or modification will have an adverse impact on such values, the NPS and FWS is most interested in additional impact analyses required under 40 CFR 52.21 (o). Specifically the applicant should provide an analysis of the impairment to visibility, soils, flora, and fauna that would occur as a

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result of the source or modification and general commercial, residential, industrial, and other growth associated with the source or modification. Also, an air quality impact analysis is required to project the result of general commercial, residential, industrial, and other growth associated with the source or modification.

Analysis of the potential adverse impacts on soils, flora and fauna should include existing vegetation types, the percent cover and biomass, spatial distribution and land use. Rare and endangered species and acidic wetlands should also be identified. Ozone concentrations and estimates of fluoride and heavy metal emissions must be supplied with pollutant baseline concentrations and pollutant contribution from all sources.

The application must include an analysis of potential visual impairment caused by the project including effects on visual range, contrast changes, and atmospheric discoloration. The magnitude, frequency, and duration of the impairment must be specified. Guidance for estimating visibility impairment is available from the EPA (Workbook for Estimating Visibility Impairment, EPA 450/4-80-031). Pictorial presentation of the results using photographs, computer simulations or artist's conceptions would be beneficial.

To assist the applicant in performing these additional impact analyses, the NPS and FWS will provide to the applicant, within 60 days of his request, a list of sensitive receptors in the potentially impacted Class I area. The applicant should submit his request to the Park Service Air Quality Division.

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Notify Regional Director at: Jurisdiction
Midwest Regional Office
National Park Service
1709 Jackson Street
Omaha, Nebraska 68102
Ohio, Indiana, Michigan,
Wisconsin, Illinois, Minnesota,
Iowa, Missouri, Nebraska,
Mid-Atlantic Regional Office
National Park Service
143 South Third Street
Philadelphia, PA 19106
Pennsylvania, Maryland, West
Virginia, Delaware, Virginia,
excluding parks assigned to
National Capital Region
North Atlantic Regional Office
National Park Service
15 State Street
Boston, MA 02109
Maine, New Hampshire, Vermont,
Massachusetts, Rhode Island
Connecticut, New York, New Jersey
National Capitol Region
National Park Service
1100 Ohio Drive, S.W.
Washington, D.C. 20242
District of Columbia, some units
in Maryland, Virginia,
West Virginia
Rocky Mountain Regional Office
National Park Service
655 Parfet Street
P.O. Box 25287
Denver, CO 80225
Montana, North Dakota,
South Dakota, Wyoming,
Utah, Colorado
Southeast Regional Office
National Park Service
1895 Phoenix Blvd.
Atlanta, GA 30349
Kentucky, Tennessee, North Carolina
South Carolina, Mississippi,
Alabama, Georgia, Florida,
Puerto Rico, Virgin Islands
Southwest Regional Office
National Park Service
P.O. Box 728
Santa Fe, New Mexico 87501
Arkansas, Louisiana, Texas
Oklahoma, New Mexico, northeast
corner of Arizona
Pacific Northwest Regional
National Park Service
601 Fourth and Pike Bldg.
Seattle, Washington 98101
Idaho, Oregon, Washington, Alaska
Western Regional Office
National Park Service
450 Golden Gate Avenue, Box 26063
San Francisco, CA 94102
California, Nevada, most of
Arizona, Hawaii

In All Cases Notify:

National Park Service
Air Quality Division
Permit Review Unit
P.O. Box 25287
Denver, CO 80225


Notify NPS Class 1 Area Superintendant at:

Acadia National Park
Route 1, Box 1
Bar Harbor, ME 04609

Arches National Park
446 South Main Street
Moab, Utah 84532

Badlands National Monument
P.O.Box 6
Interior, South Dakota 57750

Bandelier National Monument
Los Alamos, NM 87544

Big Bend National Park
Big Bend National Park, Texas 79834

Black Canyon of the Gunnison, National Monument
P.O. Box 1648
Montrose, CO 81401

Bryce Canyon National Park
Bryce Canyon, Utah 84717

Canyonlands National Park
446 South Main Street,
Moab, UT 84532

Carlsbad Caverns National Park
3225 National Parks Highway
Carlsbad, NM 88220

Capitol Reef National Park
Torry, Utah 84775

Chiricahua National Monument
and Wilderness Area
Dos Cabesas Star Route
Willcox, AZ 85643

Crater Lake National Park
P.O. Box 7
Crater Lake, Oregon 97604

Craters of the Moon National Monument
P.O. Box 29
Arco, Idaho 83213

Everglades National Park
P.O. Box 279
Homestead, Florida 33030

Glacier National Park
West Glacier, Montana 59936

Grand Canyon National Park
P.O. Box 129
Grand Canyon, Arizona 86O23

Grand Teton National Park
P.O. Box 67
Moose, Wyoming 83012

Great Smoky Mountain National Park
Gatlinburg, TN 37738

Great Sand Dunes National Monument
P.O. Box 60
Alamosa, CO 81101

Guadalupe Mountains National Park
3225 National Parks Highway,
Carlsbad, Texas 88220

Haleakala National Park
P.O. Box 537
Makawao, Hawaii 96768

Hawaii Volcanoes National Park
Hawaii National Park, Hawaii 96768

Isle Royale National Park
87 North Ripley Street
Houghton, MI 49931

Joshua Tree National Monument
74485 Palm Vista Drive
Twentynine Palms, CA 92277

Kings Canyon National Park
Three Rivers, CA 93271

Lassen Volcanic National Park
Mineral, CA 96063

Lava Beds National Monument
P.O Box 867
Tulelake, CA 96134

Mammoth Cave National Park
Mammoth Cave, KY 42259

Mesa Verde National Park
Mesa Verde National Park, CO 81330

Mount McKinley National Park
P.O. Box 9
McKinley Park, Alaska 99755

Mount Rainier National Park
Tahoma Woods, Star Routh
Ashfor, WA 98304

North Cascades National Park
800 State Street
Sedro Woolley, WA 98284

Sequoia National Park
Three Rivers, CA 93271

Olympic National Park
600 East Park Avenue
Port Angeles, WA 98302

Petrified Forest National Park
Petrified Forest National Park, AZ 86028

Pinnacles National Monument
Piacines, CA 95043

Point Reyes National Seashore
Point Reyes, CA 94956

Redwood National Park
Drawer N.
Crescent City, CA 95531

Rocky Mountain National Park
Estes Park, Co 80517

Saguaro National Monument
P.O. Box 17210
Tucson, AZ 85731

Shenandoah National Park
Route 4, Box 292
Luray, Virginia 22835

Theodore Roosevelt National Memorial Park
Medora, ND 58645

Virgin Islands National Park
P.O. Box 806
Charlotte Amalie
St. Thomas, VI 00801

Voyageurs National Park
P.O. Drawer 50
International Falls, MN 56649

Wind Cave National Park
Hot Springs, SD 57747

Yellowstone National Park
P.O. Box 168
Yellowstone National Park, WY 82190

Yosemite National Park
P.O.Box 577
Yosemite National Park, CA 95389

Zion National Park
Springdale, UT 84767

National Park Service Air Quality Program Manager
Barbara D. Brown
National Park Service
Main Interior Bldg.
18th & C Streets, N.W.
Washington, D.C. 20240
Room 3311


FWS Permit Notification List

Notify Regional Director at: Jurisdiction
U.S. Fish and Wildlife Service
Lloyd 500 Building, Suite 1692
500 N.E. Multnomah Street
Portland, Oregon 97232
Washington, Oregon, Idaho,
Nevada, Hawaii, California
U.S. Fish and Wildlife service
P.O. Box 1306
Albuquerque, New Mexico 87103
Arizona, New Mexico, Oklahoma, Texas
U.S. Fish and Wildlife Service
Federal Building, Fort Snelling
Twin Cities, Minnesota 55111
Minnesota, Wisconsin, Illinois,
Indiana, Ohio
U.S. Fish and Wildlife Service
Richard B. Russell Federal Building
75 Spring Street, S.W.
Atlanta, Georgia 30303
Arkansas, Louisiana, Mississippi,
Alabama, Georgia, Florida, North
Carolina, South Carolina, Tennessee,
Kentucky, Puerto Rico
U.S. Fish and Wildlife Service
One Gateway Center, Suite 700
Newton Corner, Massachusetts 02158
Virginia, W. Virginia, Maryland,
Delaware, Pennsylvania, New Jersey,
New York, Vermont, New Hampshire,
Maine, Massachusetts, Connecticut,
Rhode Island
U.S. Fish and Wildlife Service
P.O. Box 25486
Denver Federal Center
Denver, CO 80225
Montana, Wyoming, North Dakota,
South Dakota, Nebraska, Iowa,
Utah, Colorado, Kansas, Missouri


U.S. Fish and Wildlife Service
1011 E. Tudor Road
Anchorage, Alaska 99507

In All Cases Notify:

National Park Service
Air Quality Division
Permit Review Unit
P.O. Box 25287
Denver, CO 80225

DOI - FWS, Division of Refuges
Branch of Planning
Air Quality Specialist
18th & C Streets NW
Washington, DC 20240

Notify FWS Refuge Manager at:

Bering Sea
Clarence Rhode National Wildlife Range
Box 346
Bethel, AK 99559

Pouch #2
Cold Bay, AK 99571

Kenia National Moose Range
Box 2139
Soldotna, AK 99669

Route 2, Box 44,
Homosassa, FL 32646
St. Marks
Box 68
St. Marks, FL 32355

Wolf Island
Georgia Coastal Complex
Box 8487
Savannah, GA 31402

Box 117
Waycross, GA 31501

Box X
Calais, ME 04619

Seney, MI 49883

Venice, LA 70091

Rural Route 1, Box 9A
Puxico, MO 63960

UL Bend
Charles M. Russell
Box 110
Lewiston, MT 59457

Medicine Lake [a superscript "2" appeared here]
Medicine Lake, MT 59247

Red Rock Lakes
Monida Star Routh, Box 15
Lima, MT 59729

Great Creek Road, Box 72
Oceanville, NJ 08231

Bitter Lake
Box 7
Roswell, NM 88201

Bosque del Apache
Box 1246
Socorro, NM 87801

Route 1, Box N-2
Swanquarter, NC 27885

Rural Route 2
Kenmare, ND 58746

Wichita Mountains Wildlife Refuge
Route 2, Box 448
Indiahoma, OK 73552

Cape Romain
Route 1, Box 191
Awendaw, SC 29101

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