1. David Klemp State of Montana
PSD Workgroup
David Klemp
State of Montana

2. Tasks Assigned to Workgroup
Cumulative AQRV Impact Analysis
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
Issues discussed during November 2002 FLAG meeting in Denver

3. Cumulative AQRV Impact Analysis
States believe cumulative AQRV analysis not required and have implemented PSD permitting program this way
FLMs believe there is a basis for requiring a cumulative AQRV analysis and want this done during PSD permit review
EPA – to date hasn’t commented on lack of cumulative analysis in PSD permit reviews??
FLM attorney starting legal review of this issue
After FLM legal analysis circulated and reviewed, Workgroup will determine if EPA legal opinion is warranted

4. Increment Consumed or Adverse AQRV Impact
States will be surveyed to determine their experiences
Information received, along with the statute, will be the basis of a White Paper on these issues

5. Anticipated Schedule
Survey should be sent to states by end of April 2003
States given two weeks to respond
Depending on results and participation in survey, volunteers from the Workgroup may be solicited to draft White Paper
White Paper completed by fall 2003

6. WESTAR Council
Any questions or concerns???