EPA’s Aggregation Appeal Denied by Court of Appeals
Posted: November 16th, 2012
The 6th Circuit Court of Appeals rejected U.S. EPA’s appeal of the Court’s August 7th, 2012 aggregation decision. The August 7th decision invalidated U.S. EPA’s method of considering the functional…
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Aggregation Appeal Denied
Posted: November 15th, 2012
The 6th Circuit Court of Appeals rejected U.S. EPA’s appeal of the Court’s August 7th, 2012 aggregation decision. The August 7th decision invalidated U.S. EPA’s method of considering…
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A Time For Different Thinking Related to PSD Permitting
Posted: November 9th, 2012
U.S. EPA recently issued a New Source Review (NSR) memo on October 15th that clarifies the timeline that an applicant can expect for “timely and consistent permit processing” of a Prevention of Significant Deterioration (PSD) air permit application…
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Clarification – Pennsylvania Contemplating “RACT 2” Regulation
Posted: November 7th, 2012
On September 12, 2012, the Pennsylvania Department of Environmental Protection (PADEP) presented a draft proposed rulemaking, “Additional RACT Requirements for Major Sources of NOX and VOC” (referred to as “RACT 2”)…
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PADEP Issues Draft Technical Guidance for the Determination of Significant Figures and Timeliness of Report Submittals
Posted: October 17th, 2012
On September 8, 2012, Pennsylvania’s Department of Environmental Protection (PADEP) announced the availability of a draft technical guidance document entitled “Air Quality Program Guidance for Determination of Significant Figures…
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Did You Say “Part 70 Source” or “Par 70 Course?”
Posted: October 15th, 2012
It was around this time last year when I began playing golf. Participating in ALL4’s annual golf outing last October was my third time ever swinging clubs. I’ve been playing regularly ever since…
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Reforming U.S. EPA’s Science Advisory Process
Posted: October 8th, 2012
Science is usually just one component of environmental regulatory decision-making, but the quality and interpretation of that science often becomes the central subject of debate when regulated entities and…
Read articlePSD Permitting in Georgia – Homework Isn’t Just for Kids!
Posted: October 1st, 2012
In the spirit of a brand new school year, the Georgia Environmental Protection Division (GEPD) recently published a document that is required reading for those with air permitting interests in Georgia…
Read articleThe Sixth Circuit Court of Appeals Rejects U.S. EPA’s Functional Interrelatedness Test for Air Aggregation
Posted: September 27th, 2012
Introduction On August 7, 2012, the United States Court of Appeals for the Sixth Circuit, in a 2 to 1 decision, [1] vacated the United States Environmental Protection Agency’s (U.S. EPA) final determination that Summit Petroleum Corporation’s (Summit) commonly owned natural […]
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Exploring Plantwide Applicability Limit (PAL) Basics
Posted: September 27th, 2012
Initiating a project that triggers major new source review (NSR) requirements or an NSR applicability analysis at an existing major stationary source is arguably more difficult now than at any time since the inception of the Clean Air Act (CAA). […]
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