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PSD Workgroup

This document outlines the tasks assigned to the Workgroup concerning the Cumulative Air Quality Related Values (AQRV) Impact Analysis in the State of Montana. It emphasizes the need for a white paper to clarify the responsibilities of state agencies and permit applicants regarding cumulative analyses, especially when it comes to increment consumption or adverse impacts on AQRVs. It reflects on discussions from the November 2002 FLAG meeting, survey plans for states, and the anticipated schedule for the white paper's completion by fall 2003.

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PSD Workgroup

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  1. 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???

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