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IERG Executive Director
Deirdre K. Hirner

Environment Chamber Policy Review Archive

IERG Analyses

Summary of Governor's Climate Change Advisory Group's Draft Analyses

IERG actively participates in environmental regulatory and legislative matters that impact its Membership and reports its activities.  During the second Quarter of 2009, IERG reported the following:

Land-Related Issues

• On January 27, 2009, IERG participated in the first hearing held by the Illinois Pollution Control Board (“Board”) in the TACO rulemaking.

• On March 5, 2009, IERG submitted pre-filed questions for Illinois EPA witnesses in the TACO rulemaking.

• On March 17, 2009, IERG participated in the second hearing held by the Board in the TACO rulemaking.

Water-Related Issues

• Over the course of the quarter, IERG has actively participated in the activities of the two Regional Water Supply Planning Groups.

• IERG has continued to monitor the Chicago Area Waterway System (“CAWS”) rulemaking.

• On February 12, 2009, IERG submitted comments to U.S. EPA regarding its relisting of waters Illinois EPA removed from its 303(d) List.

Air-Related Issues

• On February 5th, 2009, Illinois EPA filed an agreed comment with IERG and the Pipeline Consortium on the Board’s First Notice version of proposed R07-19, Subpart Q.

• On February 6th, 2009, IERG filed its First Notice Comments in R07-19, Subpart Q, noting its disagreement with Illinois EPA on excluding units from averaging if they commenced operation after January 1, 2002.

• On March 30, IERG filed its Response to the Illinois EPA's Motion for Expedited Review stating it had no objection to Illinois EPA's request to move Subpart Q expeditiously to Second Notice.

• On January 20, 2009, IERG filed post-hearing comments in the NOx RACT rulemaking, asserting the Agency’s proposed NOx emissions limits go beyond what is required to meet the Clean Air Act requirements for RACT, and offering alternative options.

• On February 3, 2009, IERG participated in the NOx RACT Hearing in Collinsville.

• On March 23, 2009, IERG filed post-hearing comments in the NOx RACT Rulemaking (R08-19).  The comments reiterated IERG’s concerns with the proposal.

• On March 26, 2009, IERG filed a Response to the Illinois EPA’s Motion for Expedited Review, supporting the Agency’s motion to proceed to First Notice.

• On February 26, 2009, IERG Staff attended a meeting with representatives of the Illinois EPA Bureau of Air to discuss Subpart U, and to express concern that Member-facilities have not yet received allocations for the 2009 ozone season.

• IERG Staff continued to draft revisions to Subpart U, Part 217 to extend the current NOx trading program, to be shared with Illinois EPA.

• IERG initiated review of Illinois EPA’s proposal to sunset Subpart W, the NOx Trading Program for EGUs (R09- 20).

• IERG continued participation in MOG, now focusing on developing recommendations to assist USEPA to develop an interstate air pollution transport control program in response to the Court’s decision to remand the portion of the CAIR rule.  IERG seeks additional Member contributions to assist with this effort.

• IERG re-engaged in negotiations surrounding a draft proposal to regulate emissions of volatile organic materials in ozone nonattainment areas for various Consumer and Commercial Products when it learned of a potential impact on the continued use of solvents for previously uncontrolled cleaning processes. 

• On March 10, 2009, IERG participated in the first hearing in the rulemaking pertaining to “clean-up” changes to Illinois EPA’s air quality standards rule.

• On February 12, 2009, IERG Staff informed Members that Illinois EPA intends to move forward with making case-by-case MACT determinations. 

• On March 26, 2009, IERG met via teleconference to discuss the potential impacts of USEPA’s proposed changes to applicability of rules regulating existing stationary reciprocating internal combustion engines (RICE).  IERG intends to comment.

• IERG Staff reviewed the draft “Energy Independence for Illinois Act” on behalf of the Illinois Chamber.

Climate Change and Sustainability Issues

• The debate over whether carbon dioxide is a regulated pollutant under the Clean Air Act rages on.  Over the course of the quarter, many developments have occurred as a result of the new Administrations at both the state and federal level. 

• On March 10, 2009, IERG attended the Midwestern Climate Policy Forum in Ohio.

• On March 19, 2009, IERG advised Members not to report greenhouse gas emissions on their Annual Emission Report.

• On April 10, 2009, U.S. EPA published its proposed “Mandatory Reporting of Greenhouse Gases Rule” (74 FR 16447). 

• On April 17, 2009, U.S. EPA announced its finding that greenhouse gases contribute to air pollution that may endanger public health or welfare.

• IERG has continued to monitor House Bill 3668, which would create the Climate Action and Clean Energy Investment Act of 2009.

• The Midwestern Greenhouse Gas Reduction Accord Advisory Group continues to develop its draft Model Rule.