Not So Fast - Getting That Air Permit Won`t Be As Easy As You Think


Most of the air regulations promulgated by U.S. EPA are developed and implemented to achieve compliance with the National Ambient Air Quality Standards (NAAQS).  The NAAQS represent ambient air concentration levels that are established by U.S. EPA to ensure that the general public and sensitive subgroups of the general public are not adversely affected by air pollution.  The various NAAQS arguably represent the 'backbone' of the air quality regulatory system in the United States.  

Over the past 35 years the ambient air has become progressively cleaner as air pollution control programs and technological improvements to reduce emissions from industrial facilities and motor vehicles have evolved.  Although our air is becoming cleaner, U.S. EPA is gaining more knowledge about what levels and types of air pollutants actually affect people.  As a result, it is U.S. EPA's belief that adverse health effects still occur even at the current low ambient air concentration levels, and that if the NAAQS were lowered further, fewer people would experience air-quality related health issues. 

The Clean Air Act (CAA) requires the U.S. EPA to conduct periodic reviews of the NAAQS and, if necessary, update each NAAQS to ensure that they are protective of the general public and sensitive subgroups (e.g., children and elderly).  U.S. EPA is in various stages of reviewing and revising the NAAQS for five (5) pollutants (lead, ozone, fine particulate, sulfur dioxide, and nitrogen dioxide).  The revisions to the NAAQS will significantly affect all types of industry.  It is critical for the regulated community to understand what changes are occurring and what the ramifications are with respect to planning successfully for future operations.  Ultimately, these new standards will force emission reductions via the installation of controls or the use of lower pollutant-emitting fuels.   Keep in mind that the changes to the NAAQS are occurring on top of the additional regulatory activity involving air emissions.

Read on  as ALL4's  Colin McCall and Dan Dix cover examples and grandfathering as well as discuss the following in more detail:

  • PSD Air Quality Modeling Process
  • PM2.5 Implications
  • NO2/SO2 Implications
  • Recommendations

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