Greenhouse Gas Tailoring Greenhouse Gas Tailoring RuleRule

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GHG Permitting RuleGHG Permitting Rule

Brief History orBrief History orHow We Got to This PointHow We Got to This Point

EPA made Endangerment Finding – Dec 09EPA made Endangerment Finding – Dec 09 GHG Mandatory Reporting Rule – Oct 09GHG Mandatory Reporting Rule – Oct 09 Mobile Source GHG Rule – Apr 10Mobile Source GHG Rule – Apr 10

What Are Greenhouse Gases?What Are Greenhouse Gases?

– Carbon dioxide (COCarbon dioxide (CO22) (GWP=1)) (GWP=1)

– Methane (CHMethane (CH44) (GWP=21)) (GWP=21)

– Nitrous oxide (NNitrous oxide (N22O) (GWP=310)O) (GWP=310)

– Hydrofluorocarbons (HFCs) (GWP=12 to 11,700)Hydrofluorocarbons (HFCs) (GWP=12 to 11,700)– Perfluorocarbons (PFCs) (GWP= 6,500 to 9,200)Perfluorocarbons (PFCs) (GWP= 6,500 to 9,200)

– Sulfur hexafluoride (SFSulfur hexafluoride (SF66) (GWP=23,900)) (GWP=23,900)

COCO2 2 EquivalentEquivalent

All GHGs have an Global Warming Potential All GHGs have an Global Warming Potential (GWP)(GWP)

GWP ranges from 1 to 23,900GWP ranges from 1 to 23,900 Example:Example:

– Methane GWP is 21Methane GWP is 21– If you emit 5,000 tons of CH4,If you emit 5,000 tons of CH4,– Multiply by GWP of 21Multiply by GWP of 21

– COCO22ee emissions of 105,000 tonsemissions of 105,000 tons

Impact on PermittingImpact on Permitting

Current permitting thresholds:Current permitting thresholds:– PSD:PSD:

250 tpy250 tpy 100 tpy for listed sources100 tpy for listed sources

– Title V:Title V: 100 tpy100 tpy

EPA estimated 6 million sources would need Title EPA estimated 6 million sources would need Title V permitV permit

EPA estimated 15,550 sources under Tailoring EPA estimated 15,550 sources under Tailoring RuleRule

Permitting ThresholdsPermitting Thresholds

Effective Jan 2, 2011 (Phase 1)Effective Jan 2, 2011 (Phase 1)– ““Anyway” sources (for existing pollutants)Anyway” sources (for existing pollutants)– 100,000 tpy CO2e for PSD and Title V100,000 tpy CO2e for PSD and Title V– Applies to any existing source in permitting Applies to any existing source in permitting

program modifying by 75,000 tpy CO2eprogram modifying by 75,000 tpy CO2e

Effective July 1, 2011 (Phase 2)Effective July 1, 2011 (Phase 2)– Applies to any new or existing source of CO2e Applies to any new or existing source of CO2e

over 100,000 tpy (75,000 tpy for modifications)over 100,000 tpy (75,000 tpy for modifications)

Phase-In Step 3Phase-In Step 3

EPA rulemaking nlt July 1, 2012EPA rulemaking nlt July 1, 2012– Consider inclusion of additional sourcesConsider inclusion of additional sources– Would be effective July 1, 2013Would be effective July 1, 2013– EPA says not below 50,000 tpy (for at least 6 yrs)EPA says not below 50,000 tpy (for at least 6 yrs)

EPA to explore wide range of streamlining EPA to explore wide range of streamlining optionsoptions

Possibly permanently exclude certain sources Possibly permanently exclude certain sources from PSD, Title V or bothfrom PSD, Title V or both

What About the Future?What About the Future?

No small sources before April 30, 2016 or No small sources before April 30, 2016 or laterlater

EPA to study issue within 5 years looking at EPA to study issue within 5 years looking at admin burden if small sources pulled into admin burden if small sources pulled into programprogram

Additional rulemaking nlt April 30, 2016Additional rulemaking nlt April 30, 2016

What is Utah Doing?What is Utah Doing?

Reviewing federal programReviewing federal program Existing statutes appear to allow us to Existing statutes appear to allow us to

permit GHGpermit GHG Reviewing state rules for necessary Reviewing state rules for necessary

changeschanges Stakeholder process this fallStakeholder process this fall Tight timelineTight timeline

QUESTIONS?QUESTIONS?