David Klemp State of Montana PSD Workgroup David Klemp State of Montana

Tasks Assigned to Workgroup Cumulative AQRV Impact Analysis Survey states to determine their experiences Prepare White Paper clarifying the responsibilities of state agencies and permit applicants regarding cumulative analyses for AQRVs Increment Consumed or Adverse AQRV Impact Identify alternatives available to a state when there is either an exceedance of the increment or if there is an adverse impact on an AQRV

Cumulative AQRV Impact Analysis – State Survey Results No responding state believes that a cumulative AQRV analysis is required One state believes there is language in the FCAA that “strongly suggests” that a cumulative analysis be performed in certain instances EPA – no states reported that EPA regional offices have objected to the lack of cumulative analysis in PSD permit reviews

Adverse AQRV Impact – State Survey Results Four states identified adverse impact determinations from FLM All of these were resolved to the point a permit could be issued

Increment Consumption – State Survey Results Five states identified areas where increment may be exceeded None of these states have implemented any regulatory changes All of these states will engage in additional modeling exercises

Alternatives Available to States – State Survey Results Some responding states are not aware of or believe the FCAA clearly identifies alternatives Other responding states believe that either a SIP or permit revision is required to remedy an increment exceedance

Anticipated Schedule FLM has circulated their review of cumulative analysis issue After FLM analysis is reviewed and some of these issues are discussed at the increment tracking workshop, Workgroup will determine if EPA legal opinion is warranted Depending on the outcome of the increment tracking workshop, volunteers from the Workgroup may be solicited to draft White Paper White Paper completed by fall 2003

WESTAR Council Any questions or concerns???