Minnesota
Power
EPA
Meeting
EPA
CAIR
Reconsideration
February
2,
2006
Key
Points
Minnesota
Exclusion
 
Minnesota
emission
inventory
corrections
result
in
lower
SO2
and
NOx
emissions
for
EPA
2010
projections.
o
Corrected
overstated
EPA
2010
estimated
emission
rates
using
2001
CEMS
emission
rates..
o
Included
Taconite
Harbor
Energy
Center
emissions
and
adjusted
Laskin
Energy
Center
NOx
emissions.
o
Balanced
the
2010
heat
input
for
Boswell
units
 
Environ/
Alpine
Geophysics
model
runs
considering
these
corrected
emissions
confirm
the
Minnesota
emissions
impact
on
Chicago
area
air
quality
is
not
significant
 
CMAQ
Version
4.5
corrects
a
mass
conservation
error
in
CMAQ
Versions
4.3
and
4.4
and
affirms
even
less
of
a
Minnesota
emissions
transport
impact.

Allowance
Allocation
Equity
 
The
CAIR
SO2
allowance
allocation
carryover
from
the
Acid
Rain
Program
is
inequitable
to
states
like
Minnesota
that
had
already
provided
for
significant
SO2
emission
reductions.
 
Minnesota
Power
supports
the
heat
input
with
fuel
type
bias
allocation
approach
proposed
by
Santee
Cooper.
 
Minnesota
Power
suggests
that
natural
gas
fired
generation
be
excluded
from
SO2
allowance
program
participation
when
it
is
demonstrated
that
natural
gas
is
delivered
meeting
industry
sulfur
content
standards.
