RACT 2 Rule Published: Clock Starts on RACT 2 Proposals – “The trouble is, you think you have time.” – Gautama Buddha
Posted: May 5th, 2016Authors: Ron H.
The internet is confused and gives me contradictory answers as to whether the title of this blogpost is a legitimate quote uttered by the Buddha himself or a paraphrase – authored by some Western scholar and without context I’m sure – of a Buddhist teaching. If I was a betting man, I’d say it’s probably the latter. Regardless of its historical authenticity (and original context), the sentiment expressed is perfect for my intended purpose here. Anyway…
On April 23, 2016, the RACT 2 Rule was published final in the Pennsylvania Bulletin. That bears repeating – As of April 23, 2016, the RACT 2 Rule was published final in the Pennsylvania Bulletin. We have arrived. It has happened. We’ve been talking about this for months. Talking and waiting, talking and waiting…a lot of talking and a lot of waiting. Honestly, it was starting to feel like we were crying wolf a bit, but then the Environmental Quality Board (EQB) published the final RACT 2 Rule on April 23rd. Finally and not a moment too soon let me tell you. Personally, I’m relieved. The suspense is over. The anticipation has ended. The rule is here. Now what? What does that mean for you?
Well, if you’re a major source of either of the ozone precursor pollutants (i.e., NOX and/or VOC), meaning that you have the potential to emit greater than 100 tons of NOX and/or greater than 50 tons of VOC, and you operate within the Commonwealth of Pennsylvania, you are subject to the RACT 2 Rule and need to evaluate its applicability to your NOX and VOC emitting sources ASAP. I know that people use the acronym ASAP flippantly…“Can I have that ASAP?” “Call me ASAP!” “I need that report ASAP!” It’s a term all but devoid of meaning at this point. That said, when I use the term ASAP in reference to the RACT 2 Rule I do mean as soon as possible; without a moment to spare. Here’s why…
RACT 2 proposals or alternative RACT 2 petitions need to be submitted to PADEP by October 24, 2016 and facilities must be able to comply with applicable RACT 2 requirements by January 1, 2017. We are now within six (6) months of the submittal date and well within a year of the compliance date. So when I say ASAP, I literally mean ASAP. As the Buddha may or may not have said, “The trouble is, you think you have time.” In actuality, with regard to RACT 2, you don’t.
First time you’ve heard of this? Want to know more about what these regulations could mean to major sources of NOX and VOC in the Commonwealth? Go here and read all about it in ALL4’s previous RACT 2 blogs or reach out to firstname.lastname@example.org or (717) 822-0009 or me at Ron Harding at email@example.com or (610) 933-5246 extension 119.