SUBJECT:
NOx RACT Meeting Summary
On June 23, 2008, IERG Staff met with IERG Members to discuss the Illinois EPA’s NOx RACT proposal filed with the Board on May 9, 2008. Members discussed several fronts on which industry could challenge the proposal as whole, and discussed in detail particular sections of the proposal that still need clarification and revision. We have attached a summary of the meeting for your review.
Subject:
RESPONSE REQUESTED -
Subpart U Allocations
IERG is assembling its draft proposed rule to replace Subpart U and have the NOx trading program operate under the CAIR program. As part of this effort, we need to revisit the NOx allocations that each member WOULD LIKE TO HAVE and MUST HAVE. We requested this information in an E-mail dated June 9th which contained a summary of a meeting held with Rob Kaleel, wherein he provided the Agency’s concepts of a revised program. So far, we have only received responses from ADM, Bunge, Marathon, Duke Energy and Tate & Lyle. In order for IERG to complete its draft Subpart U rule to submit to Illinois EPA, it is extremely important that Members respond.
Please review the attached spreadsheet and
respond to IERG Staff no later than FRIDAY, JULY 11, 2008.
SUBJECT:
Harry Walton has analyzed the affect that the
proposed groundwater standards would have on site remediation under
TACO, and the use of TACO as a justification for adding some of the
proposed contaminants. The attached memo contains Harry’s
analysis.
SUBJECT: Notes:
groundwater rulemaking hearing
On June 18, 2008, Alec Davis attended the
Pollution Control Board hearing in Chicago dedicated to the (R08-18)
Proposed Amendments to Groundwater Quality Standards rulemaking.
Attached, please find Alec’s notes, including IEPA’s responses
to the 9 questions asked on behalf of IERG, and the 21 asked by the
Board.
SUBJECT: Proposed
Agenda and Summary of NOx RACT Rule for 6/23/08 Meeting
We have attached the proposed Agenda for the June 23rd meeting on the NOx RACT Rule. Also attached is a summary of the Rule as compared to IERG’s last set of comments to the Illinois EPA, the “final” Rule as proposed by the Agency, and the Appendices. Should you be interested in reviewing the Agency’s Statement of Reasons or additional information pertaining to the Rule, you may access it on the Board’s website (link is available on Memorandum below).
SUBJECT:
Consumer
Products Rulemaking Hearing Summary
On June 4, 2008, attorneys from Hodge Dwyer
Zeman, on behalf of IERG, attended a Pollution Control Board hearing
dedicated to the Illinois EPA rulemaking proposal: Proposed New 35
Ill. Adm. Code Part 223 Standards and Limitations for Organic
Material Emissions for Area Sources (R08-17) (“Consumer Products
Rulemaking”). IERG
Staff understands that Members have expressed no concern with the
particular substance of the proposed rule; however, we believe that
the actions of the Illinois EPA in proposing this rule necessitated
IERG’s involvement.
Subject:
Subpart U meeting With IEPA
Attached is a summary of the meeting Dave Kolaz
had with Rob Kaleel regarding Subpart U. Also attached is a
document that Rob prepared which served as the basis for Illinois
EPA’s internal discussion on continuation modification of the
rule.
For your convenience, we have included the
Summary of NOx Budget Allocations and Usage 2004 – 2006 IERG
prepared and circulated previously.
Importantly, Members should indentify the
number of allowances they would prefer or need to have allocated for
their individual facilities under any new Subpart U proposal.
We need your thoughts. Please reply by June 13th.
SUBJECT: Environmental Fees Question and Answer
As the Members surely know, the General Assembly passed the Governor's huge fee increase bill this last legislative session in an effort to provide funding for the Agency and to fill the state's budget hole. Since the Governor signed this bill, these fees are now law, and the Agency is in the process of implementing the increased and new fees. With this implementation comes many questions. IERG Staff will answer these questions as they arise, and will add them to our growing list of 'Environmental Fees: Questions and Answers.