On March 13, 2018, U.S. Environmental Protection Agency Administrator Scott Pruitt issued a memorandum reinterpreting EPA regulations that determine when a project could trigger new source review, or NSR. This new interpretation of the NSR regulations allows permittees to consider the overall emission impact from a proposed project from a macro-level perspective considering a wide range of impacts a project may have throughout an existing facility. If the proposed project does not cause a significant emissions increase based on this holistic analysis, there is no need to conduct the detailed netting analysis currently in the regulations, which examines all increases and decreases throughout a facility in the previous five years. This new interpretation implements a high-priority NSR reform from the last Republican administration that was not completed before the Obama administration took office, and makes it easier for permittees to proceed with plant improvements without the delays inherent in the NSR review process.
How Is EPA's New Source Review Guidance Helpful?
April 13, 2018