Record of Meetings with States 

Relating to PSD Interpretive Memo Reconsideration and Tailoring Rule

February 2010

EPA and the National Association of Clean Air Agencies (NACAA) held a
series of meetings during February 2010 relating to state and local
agencies' PSD and Title V regulations.  Specifically, the discussions
related to NACAA’s public comments that recommended applying PSD to
GHGs upon the date the proposed GHG standards for vehicles would “take
effect” and the potential need for some states to amend state laws to
implement the provisions in the proposed Tailoring Rule.  In these
conversations, EPA and NACAA discussed how existing state regulations
incorporate the phrase “subject to regulation” and the extent to
which agencies have interpreted it and the considerations regarding how
they may interpret in the future.

This topic was discussed generally at an initial meeting with NACAA
staff at EPA Headquarters on February 2, 2010 and an EPA/NACAA retreat
held in Washington, DC on February 4, 2010.

Specific follow-up calls were held on:

2/8 with representatives from EPA and the Connecticut Department of
Environmental Protection. 

2/9 with representatives from EPA and the Michigan Department of Natural
Resources and Environment.

2/10 with representatives from EPA, NACAA, Ohio EPA, and the Colorado
Department of Public Health and the Environment.

2/12 with representatives from EPA, NACAA, the New York State Department
of Environmental Conservation, the Kentucky Department for Environmental
Protection, and the Sacramento Metro Air Quality Management District.  

