- WEB EXCLUSIVE
- PE COFFEEHAUS
The EPA on Thursday, Nov. 10, 2010, finally released its long-awaited PSD and Title V Permitting Guidance for Greenhouse Gases.
The agency recommended that permitting authorities use the best available control technology (BACT) process to look at all available emission reduction options for GHGs. After taking into account technical feasibility, cost and other economic, environmental and energy considerations, permitting authorities should narrow the options and select the best one. In a press release, the EPA said it anticipates that most BACTs will likely concern a lot of energy efficiency (as opposed to capture or control).
The guidance does not define or require a specific control option for a particular type of source because BACT is determined on a case-by-case basis. Instead, the guidance and resources provide the basic information that permit writers and applicants need to address GHGs. The guidance also provides examples of how permitting requirements could apply.
The requirements are clear for BACT, but do leave room for heavy-handed interpretation by state regulators. For example, the guidance suggests that permitting agencies, "take a 'hard look' at the applicant's proposed design in order to discern which design elements are inherent for the applicant's purpose and which design elements may be changed to achieve pollutant emissions reductions without disrupting the applicant's basic business purpose."
This is the New Source Review end of the GHG control: beginning in January 2011, industries that are large emitters of GHGs, and are planning to build new facilities or make major modifications to existing ones, will work with permitting authorities to identify and implement BACT to minimize their GHGs. This includes the nation's largest GHG emitters, such as power plants, refineries and cement production facilities. Emissions from small sources, such as farms and restaurants are not covered by these GHG permitting requirements. A more national cap-and-trade program would be in addition to the BACT requirements under the Clean Air Act.
The EPA is accepting comment through Dec. 10, 2010.
SOURCE: EPA press release
Read the guidance document.