 From:
Sam Portanova/R5/USEPA/US
 To:
Pamela Blakley/R5/USEPA/US@EPA
 Cc:
Beth Valenziano/R5/USEPA/US@EPA
 Date:
12/02/2010 12:03 PM
 Subject:
Phone Conversation Record (Dec 2 call with IDEM on T5 GHG issues)


As a follow up to our 11/30/10 conversation with IDEM (see summary below), Region 5 participated in a more detailed conference call with IDEM on 12/2/10.  Participating from Region 5 were Sam Portanova and Beth Valenziano from ARD and Jane Woolums from ORC.  

Participating from IDEM were Ann Long (Office of Legal Counsel); Susan Bem (staff), Chris Pedersen (section chief), and Scott Deloney (branch chief) from IDEM's rule developing branch; Matt Stuckey (branch chief, air permitting branch); and Keith Baugus (assistant commissioner for air).

On this call, IDEM agreed that their existing Title V regulations do not provide authority to permit GHGs at any level.  Regarding the rule revisions that are currently in the process of adoption, IDEM believes the rules can be interpreted to allow for GHG permitting.  Region 5 believes the new rule language is ambiguous, but agrees that IDEM can supplement these rules with an Attorney General opinion letter stating the intention of the rule to allow for GHG permitting under Title V.   

Regarding the timing of a Title V program update submittal to incorporate these rules, IDEM says they plan to hold off on a Title V submittal until they receive more guidance from EPA on what needs to be included in that submittal.  Region 5 agrees with this approach.

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