"that state permitting
authorities have not had sufficient time to develop necessary
permitting infrastructure and to increase their GHG permitting
expertise and capacity. By the same token, EPA and the state
permitting authorities have not had the opportunity to develop and
implement streamlining approaches.
In other words, subjecting more facilities to the GHG rule
would still pose a risk of tying the system in knots, so EPA's
not going there – at least not yet.
EPA also promulgated some revisions to 40 CFR Part 52 to
facilitate use of plantwide applicability limits for GHG
sources. Most importantly, the regulations will permit
GHG-only sources (sources that are not major sources for non-GHG
pollutants) to utilize GHG PALs and retain their minor source
status with respect to other pollutants.
EPA is fond of describing its GHG regulatory program as a common
sense approach. It is certainly true that, so long as EPA
regulates GHGs under existing CAA authority, today's rule
qualifies as common sense. It's still not going to please
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The U.S. Environmental Protection Agency has published a proposed rule entitled Response to Petition for Rulemaking; Findings of Substantial Inadequacy; and SIP Calls to Amend Provisions Applying to Excess Emissions During Periods of Startup, Shutdown, and Malfunction.
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