Proposed Permit Fee Incentive Rulemaking

Conference Call with ASIWPCA - 12/8/06 - 4:00pm

EPA Participants:

Leonard Bechtel

Lena Ferris

Benjamin Grumbles

ASIWPCA Participants:

Linda Eichmiller

Marcia Willhite, Illinois EPA, President of ASIWPCA

ASIWPCA raised the issue of their continuing concern regarding the
change in the Section 106 allocation and that funds continue to be
designated outside the formula.  

Benjamin Grumbles articulated his commitment to follow through on the
language in the President’s budget in a modest and incremental way.  
EPA is committed to gathering more information before the Agency goes
final and we look forward to a very robust comment period.

Commitment made by EPA to follow-up with States during the comment
period.

Proposed Permit Fee Incentive Rulemaking

Meeting with Fred Andes – 12/14/06 – 4:30pm

Fredric P. Andes, Esq.

Partner, Barnes & Thornburg LLP

Suite 4400

One N. Wacker Drive

Chicago, IL  60606-2809

EPA Participants:

Leonard Bechtel

Lena Ferris

James Hanlon

Robert Moyer

Paul Versace

Additional Participants Included Representatives From:

AISI

Dow Chemical

EEI

Ken Kirk, NACWA

U.S. Steel

The participants voiced their concerns over the upcoming proposed
rulemaking.  Specifically, their discussion focused on States that do
not have authority to apply permit fees, and how this proposed rule
would impact their ability to receive a portion of Section 106 funds. 
Issues covered in the discussion also included:  EPA’s authority to
issue this rulemaking; what the Agency means by “incentive” program;
and also what the Agency means by “adequate permit fee program.” 
All these issues were addressed generally, with specifics being withheld
until the publication of the proposed rulemaking.

Commitment made by EPA to follow-up with industry and States during the
comment period, through public meetings or workshops.

Proposed Permit Fee Incentive Rulemaking

Conference Call with Katie Williams (with Senator Ted Steven’s Staff,
AK) – 12/15/06 – 11:00am

EPA Participants:

Leonard Bechtel

Tom Dickerson

Lena Ferris 

Paul Versace

Senator Steven’s staff expressed their concerns over the upcoming
proposed permit fee rulemaking.  Discussion focused on the definitions
of “incentive” and “adequate permit fee program.”  EPA provided
some general background on the evolution of the proposed rulemaking, its
current status, and the intent and purpose of the proposed rule.

EPA indicated that once the rule was proposed, the Agency was committed
to providing for workshops and public meetings to better inform industry
and States about the impact of the rule, and to follow-up with Senator
Steven’s staff, should they have more specific questions once they
read the proposed rule.

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