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

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. WESTAR Council
Any questions or concerns???