Arcadis

A Practical Guide to NSR Reform

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Courtesy of Arcadis

As discussed in detail in the March 2003 Issue of EM, the U.S. Environmental Protection Agency (EPA) promulgated a series of reforms to its New Source Review (NSR) permitting program starting on December 31, 2002. These reforms are commonly referred to as “NSR reform.” EPA asserts that the reforms reduce administrative burden, maximize operating flexibility, improve environmental quality, provide additional certainty, and promote administrative efficiency. Whether EPA’s assertions are accurate has been the subject of considerable debate, but the agency arguably did not achieve one of its original goals of eliminating program complexity. In fact, the reforms did not eliminate anything substantive from the NSR program.

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