Greenhouse Gas (GHG) Permit Training

Other Aspects of PSD Title V Permitting

Other Aspects of PSD Implementation

Air Quality and Impact Analyses:GHG Specific Considerations

• Since no NAAQS or PSD increments exist for GHGs, PSD applicants are not required to model GHGs or conduct ambient monitoring for GHGs.

• While GHGs will induce warming and impact the environment, including Class I areas and soil and vegetation, it is not feasible with current climate change modeling to detect and attribute such impacts to a specific source of GHGs in permit review.

DRAFT 3

GHGs and Title V

Title V Considerations

• Title V permit must contain conditions necessary to ensure compliance with applicable requirements for GHGs (e.g., PSD permit conditions)

• Title V applications (including permit revision, reopening or renewal) are required to provide emissions information for all pollutants for which it is considered “major”

• Under Step 1 of Tailoring Rule, a new or modified stationary source cannot be "major" solely on basis of GHG emissions– So not all applicants required to provide GHG emissions information– However, permitting authority can request GHG emissions

information from applicant to verify that PSD was not triggered by a GHG source

5DRAFT

Title V Considerations (cont’d)

• Under Step 2, a stationary source can be "major" solely on basis of GHG emissions if it exceeds the 100,000 tpy CO2e threshold– So permit applicants over the threshold must provide GHG

emissions data (in addition to information for all other air pollutants for which they are major)

– Particularly in cases where there are no applicable requirements for the GHG emission source, a description of the source (instead of an emission estimate) may be sufficient (see 1995 Title V policy guidance White Paper #1)

– Sources newly subject to Title V solely because of GHG emissions will still need to provide required information for all applicable requirements under Clean Air Act (e.g., requirements in a SIP). Appropriately, as for other applicable requirements, monitoring, recordkeeping and reporting conditions will be required for those requirements.

6DRAFT

Title V Considerations (cont’d)

Summary of Title V Applicability Criteria for Sources of GHG

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January 2, 2011 to June 30 2011(Step 1 of the Tailoring Rule)

On or after July 1, 2011(Step 2 of the Tailoring Rule)

No sources are subject to title V permitting solely as a result of their emissions of GHGs.

(Thus, no new title V sources come into the title V program as a result of GHG emissions.)

The following sources are subject to title V permitting as a result of their GHG emissions:• Existing or newly constructed GHG emission sources (not already subject to title V) that emit or have a PTE equal to or greater than:• 100,000 TPY CO2e; and• 100 TPY GHGs mass-basis

DRAFT

Title V Considerations (cont’d)

• Note that in Step 2, as under Step 1, for all “anyway sources” subject to title V, sources and permitting authorities need to meet the generally applicable title V application and permitting requirements as necessary to address GHG applicable requirements established under other CAA programs (e.g., the PSD program)

• It is expected, at least at the outset, that this will consist primarily of meeting application and permitting requirements necessary to assure compliance with PSD permitting requirements for GHGs.

8DRAFT

Title V Considerations (cont’d)

• GHG emissions reporting under Mandatory Reporting Rule not currently considered an "applicable requirement" under EPA regulations implementing Title V; so this reporting requirement does not need to be included in the Title V permit.

• EPA is not changing its title V fee regulations or requiring new fee demonstrations from states at this time. However, permitting authorities must collect fees to cover the costs of processing title V permits for major GHG sources. ???

• EPA flexible permitting provisions extend to GHG sources. Permitting authorities and permit applicants, may find that PALs, alternative operating scenarios and advanced approvals are useful when energy efficiency measures are being considered that reduce GHGs.

9DRAFT