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Model Rule/MOU Update and Workshop. Bob Lebens, WESTAR Council Air Managers Committee Presentation May 23, 2002. Model Rule/MOU Background. Draft Model Rule/MOU included in Annex To implement backstop trading program MTF Work Plan recommended MOU/Model rule update
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Model Rule/MOU Update and Workshop Bob Lebens, WESTAR Council Air Managers Committee Presentation May 23, 2002
Model Rule/MOU Background • Draft Model Rule/MOU included in Annex • To implement backstop trading program • MTF Work Plan recommended MOU/Model rule update • MTF recommended that WESTAR update Model Rule/MOU • MTF recommended AMC administer contract
Need For Update/Workshop • Trading Programs are rare in western states • Agency rule writers are unfamiliar with draft Model Rule/MOU • 309 SIP process will begin Fall 2002 • Regional consistency is necessary in a trading program
Rule/MOU Update Needed to: • Incorporate ‘Supplement to the Annex’ • Incorporate EPA comments • Ensure consistency with ‘other’ federal requirements (i.e. NOx SIP call, EIP) • Ensure consistency with state and tribal regulatory structures • Ensure Model Rule/MOU contain appropriate provisions
Proposed Approach – Phase I • Assemble Working Group • Review Model Rule/MOU in detail • Review other Trading Programs
Corky Martinkovic, AZ Rita Trujillo, NM Colleen Delaney, Lenore Epstein, UT Tina Jenkins, WY Bob Gruenig, NTEC Other Tribal reps? Lee Alter, WRAP Lily Wong, EPA Kristin Gaston, Bob Lebens, WESTAR Working Group
Proposed Approach – Phase II • Refine Work Plan w/working group input • Educate agency staff about Model Rule/MOU • Hold Working Group Meeting to Update Model Rule/MOU • Hold Workshop to educate broader audience