NSR Reform: Shaping Project Emissions Accounting for Your Capital Projects
U.S. EPA continues to reshape the New Source Review (NSR) applicability process through targeted policy guidance documents – the latest covering project emissions accounting (Step 1 of the applicability process). The policy revisions are helpful and inject a measure of common sense into an applicability process that was sorely lacking it. However, note that the revisions will not always make NSR applicability determinations simpler. The NSR program remains complicated, and while the reforms are welcome, the need to evaluate air permit strategies very early in the project planning process is more important than ever given the evolving changes to the program and the need to fully utilize the reforms that are becoming available.
State regulatory agencies are digesting the guidance and will be looking for implementation assistance. Many of the agencies have their own state implementation plan-approved NSR programs, so U.S. EPA guidance will not always be automatic. Strategy and planning for capital projects goes beyond a simple question of “what are the implications?” and highlights the need for industrial stakeholders to take a leadership role in working with state agencies to develop a solid NSR applicability process.
With that backdrop, this webinar addresses three questions:
- What are the technical aspects of U.S. EPA’s project emissions accounting guidance?
- How can I apply them to my projects?
- What key approaches can I use to take a lead role with my state agency in developing an applicability process that works?
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