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The U.S. Environmental Protection Agency (EPA) sets National Ambient Air Quality Standards (NAAQS) to protect public health and welfare. The NAAQS define the maximum acceptable concentrations of certain air pollutants, and thereby the amount of air resources that must be shared by all industrial facilities and other sources of those pollutants.
When the Iowa Department of Natural Resources (DNR) receives an air quality construction permit application, there may be a determination, through computer-aided air dispersion modeling, of the concentration of air pollutants in the ambient air near the facility. This includes any impact the facility may have as well as impacts from nearby facilities. The DNR compares these impacts to the NAAQS to ensure that public health is protected, and summarizes this information in the form of an Availability of Air Resources (AAR) Summary.
When available, an AAR Summary is provided to permit applicants upon permit issuance. The applicant can then use the AAR Summary for planning purposes and to assist in the preparation of future permit applications. AAR Summaries may also be requested using the contact information on this page.
How do I request an AAR Summary?
Use the contact information on this webpage. Be sure to provide the facility name and city, as well as the Plant ID (if known). The AAR Summary will be sent to the email address used to make the request. Alternatively, you can contact the DNR at 515-725-8200 (ask to speak to a member of the dispersion modeling team).
Can I review the information used to produce the AAR Summary?
Yes. The electronic modeling files and full technical reports associated with the information contained in the AAR Summary are available upon request, using the contact information on this page. This information is only available electronically and cannot be sent via mail.
Is there any cost associated with requesting an AAR Summary?
Requests for a single location will be fulfilled at no cost. Representatives of facilities with multiple locations may request an AAR Summary for each of those locations at no cost. Other bulk requests will be referred to the DNR record center and may be subject to a database search fee depending on how long it will take to fulfill the request.
Can I request an AAR Summary for any location?
Yes. However, the DNR can only provide this information for areas in the immediate vicinity of industrial sources where data from a comprehensive air quality analysis already exists. Requests for AAR Summaries for areas of the state where no data exists cannot be fulfilled.
How does the AAR assist the DNR in protecting air quality?
When an air pollutant concentration, predicted by computer-aided dispersion modeling, approaches the air quality standards for that pollutant, it becomes more likely that public health and welfare would not be protected if additional emissions of those air pollutants are permitted.
The DNR uses concentration levels referred to as Modeling Determination Thresholds (MDT) as an indicator that an area is approaching the applicable National Ambient Air Quality Standards (NAAQS).
If the facility’s impact is equal to or greater than the corresponding MDT, then the majority of the air resources in the area are already being utilized. For this reason an air dispersion modeling analysis will be required the next time the facility submits a non-Prevention of Significant Deterioration (non-PSD) permit application to increase the emission levels of any pollutant that is currently at or above an MDT. (For PSD projects, an air dispersion modeling analysis is generally required as part of an air quality analysis of ambient impacts associated with the project.)
The modeling analysis is used to predict the future concentration of air pollutants generated by the proposed project, which will help ensure that the project is designed in such a way that the area will continue to meet the NAAQS.
I do not have an AAR Summary for my facility. How can we know if our proposed construction project will be required to be modeled?
If you have not already done so, request an AAR Summary from the DNR using the contact information on this page. If an AAR Summary is not available then the availability of air resources will not be considered when determining if modeling will be required.
For non-Prevention of Significant Deterioration (non-PSD) projects, all facilities are required to submit Form MD (Non-PSD Modeling Determination Form). This form also requires the facility to document any pollutant emissions increases due to the project. If emissions exceed the Significant Emission Rate (SER) threshold for any pollutants, then modeling is required for those pollutants. In addition, there may be other considerations on a case-by-case basis, where DNR may determine that modeling is required.
For PSD projects, an air dispersion modeling analysis is generally required as part of an air quality analysis of ambient impacts associated with the project.
What sources of air emissions influence the availability of air resources in my area?
The box at the top of the AAR Summary lists all the facilities that may directly affect the air quality in the area. These facilities were the focus of the modeling analyses used to estimate the amount of air resources currently being utilized. All other sources of air emissions are included in the modeling analyses as part of the background concentration.
How is the amount of available air resources determined?
The amount of available air resources is determined using a computer simulation called a dispersion model. The dispersion model is used to predict the maximum concentration (defined by the form of the standard for the pollutant and its averaging time) caused by emissions from industrial sources in the area. In order to make this prediction, information about the area being evaluated is entered into the dispersion model. This can include: the amount of pollution being released into the air, the height of smoke stacks that the pollution is coming from, and the area’s terrain and weather conditions. The modeled concentration is then added to the background concentration to determine the total predicted pollutant concentration in the area. Subtracting the total concentration from the NAAQS provides an estimate of the amount of air resources that is still available in the area.
If the amount of air resources still available in the area is very small, does this mean the area cannot support additional industrial growth?
Not necessarily. The results from dispersion modeling represent the location(s) of maximum concentration in the area, usually near the largest air emission source(s). The concentration at all other locations in the area will be something lower than this value. It may be possible to design new projects in such a way that minimizes the impact of the additional emissions on the existing point of maximum concentration, or to modify existing emission sources to alleviate the area of high concentration. Dispersion modeling is the appropriate tool to use for this purpose.
The total concentration on the AAR Summary exceeds the National Ambient Air Quality Standards (NAAQS). What does this mean?
There are a few reasons why this might occur. When the concentration is only slightly over the NAAQS, it is most likely due to rounding. The AAR Summary includes the unrounded model concentrations because these are the values that should be used when filling out Form MD as part of the application process. However, for non-Prevention of Significant Deterioration (non-PSD) projects, the concentration for some pollutants are rounded before being compared to the NAAQS. For example, a 24-hour PM10 concentration of 154 rounds down to 150, which meets the NAAQS for that pollutant. If instead, the concentration is considerably higher than the NAAQS, then it is more likely that the analysis actually resulted in predicted exceedances, but that the applicant was able to show that they do not have a significant concentration at those predicted exceedances (emission sources that do not significantly contribute to a predicted exceedance may be permitted). This is often due to conservative assumptions being used in the modeling analysis, but could also signify the need to reevaluate the permit conditions for the source(s) causing the predicted exceedances. Another possibility is that the background concentration may have increased since the analysis was conducted. Future projects will need to be evaluated in a dispersion modeling analysis for the affected pollutant(s).
How can I use the AAR Summary for planning purposes?
Knowing the amount of air resources still available in your area can help gauge the impact on air quality permitting projects. Projects are less likely to need additional pollution controls, design modifications, or permit limits in order to meet the NAAQS if there is a majority of the air resources still available. If the NAAQS is not far above the background level for a pollutant, air resources for that pollutant may be limited even though the industrial impacts from that pollutant in the area are low.
The amount of air resources still available will also determine whether a modeling analysis will be required the next time an air permit application is submitted. For projects that involve an increase in emissions, a modeling analysis will be required for pollutants that are at or above one or more of the MDTs (Modeling Determination Thresholds. If there are pollutants that are close to the MDT, it may be beneficial to conduct a dispersion modeling analysis prior to pursuing future projects. Doing so will allow the impact of the facility’s emissions to be considered as part of the site selection and engineering design process.
What is a Modeling Determination Threshold (MDT)?
A Modeling Determination Threshold (MDT) is a concentration level used by the Iowa DNR as an indicator that an area is approaching the applicable National Ambient Air Quality Standards (NAAQS). The MDTs vary based on pollutant and averaging period, and define when a permit application will require a modeling analysis. Each MDT is equal to the NAAQS for the pollutant of interest minus the applicable Significant Impact Level (SIL).
What are the National Ambient Air Quality Standards (NAAQS)?
The National Ambient Air Quality Standards (NAAQS) are concentration levels set by the Environmental Protection Agency (EPA) to protect public health and welfare. The NAAQS define the maximum acceptable concentrations of certain air pollutants, and thereby the amount of air resources that must be shared by all industrial facilities and other sources of those pollutants.
What is a Significant Impact Level (SIL)?
A Significant Impact Level (SIL) is a concentration level for a given pollutant below which emissions of that pollutant will not cause or contribute to a violation of the NAAQS. The SILs are proposed by EPA and vary based on pollutant and averaging period.
What is a background concentration?
Background concentration represents the existing level of pollutants in the air without the influence of nearby industrial facilities. The background includes natural sources, non-industrial human activity, and distant industrial facilities.
What is ambient air?
Ambient air refers to the air outside the boundary of a facility where its emissions will have an impact on the public.
To request an AAR Summary, contact us directly at: firstname.lastname@example.org
(be sure to include the ##-##-### plant ID number)