Permitting Program Overhaul Rulemaking
• Revise Nonattainment/Maintenance Area Requirements:
Permitting Requirements for Non-Federal Major Sources in Nonattainment Areas | |
Existing Rules | Proposed Rules (after NAAQS achieved but before redesignation) |
Lowest Achievable Emission Rate (LAER) controls (no economic analysis) | Best Available Control Technology (economic analysis) |
Emission offsets from other sources | Emission offsets from other sources |
Net Air Quality Benefit Analysis - modeled impacts at majority of receptors decreased and SIL or less at every receptor | Net Air Quality Benefit achieved through offsets |
• Add provisions for areas that exceed national ambient air quality standards but are not yet designated as nonattainment. Without this rule or the nonattainment area designation, sources in these areas are unable to build because they cannot meet the modeling requirements since the background concentration is already over the standard.
• Move procedural requirements from definitions to the divisions where other procedural requirements reside.
• Repeal outdated or statewide generic rules that are less stringent than other source specific state or federal requirements.
• Tighten grain loading and opacity standards for older sources that were built before June 1, 1970. There are a few sources that may be unable to meet the lower standards.
• Clarify requirements for:
◦ how emergency generators should be permitted,
◦ how to permit sources that want to be combined or split, and
◦ how sources should determine compliance.
• Update continuous monitoring and source test manuals that were adopted by the EQC in 1992.
• Change rules to improve permit timeliness:
◦ Require earlier renewal applications
◦ Extend some permits to 10 years, if possible
◦ Require pre-application informational meetings
◦ Limit applicant review of draft permit to 14 days