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Quarterly Meeting List of Documents


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. 

  View Memorandum


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.

View Memorandum


SUBJECT:    RESPONSE REQUIRED:  Groundwater (Part 620) Issues, and the Impact on TACO (Part 742)         

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.  

View Memorandum


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.  

View Memorandum


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). 

View Memorandum


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.  

View Memorandum


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.

View Memorandumz


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.

View Q & A

Part 620