Solving Air Permitting Gridlock
New Source Review (NSR) is a permitting process under the Clean Air Act that requires manufacturing facilities to undergo a review of both their environmental impact and control equipment when a major modification is made or new facility is built. NSR focuses on the pollutants covered by National Ambient Air Quality Standards (NAAQS), such as particulate matter or nitrogen oxides.
To obtain a permit, facilities must demonstrate that emissions from the project, when combined with background air quality, do not exceed the applicable NAAQS threshold. Too often, unrealistic assumptions (models, methods, emissions, etc.) or EPA policies exaggerate a project’s impacts so it is incorrectly labeled as a major modification, which triggers additional requirements. Consequently, the project must either be significantly reworked or cancelled. This can discourage efficiency and emissions improvements. It can also increase unnecessary costs and cause delays.
AF&PA believes that EPA should:
- Use more realistic receptor locations
- Fairly account for net project emissions
- Avoid inappropriate bundling of unrelated projects
- Embrace dispersion modeling improvements
- Support better emission test methods
- Use best estimates of background and project emissions
- Streamline permitting process to reduce delays and burdens
- Reestablish its partnership with states and give them deference in running the permitting program
Related: Air Permitting Problems and Solutions One Pager (PDF) | Modernize Air Permitting (JPG)