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Greenhouse Gas (GHG) Emissions and Air Quality Permitting
On June 3, 2010, the U.S. Environmental Protection Agency (USEPA) issued a final rule that sets applicability thresholds for greenhouse gas (GHG) emissions defining when permits under the New Source Review Prevention of Significant Deterioration (PSD) and Title V Operating Permit programs are required for new and existing sources. This rule is known as the “Tailoring Rule.”
The Tailoring Rule primarily targets sources of combustion, but it may affect other sources that are modifying or applying for new Permits to Install (PTIs) and Renewable Operating Permits (ROPs). If you have emissions of any of the following pollutants, you may be affected by the Tailoring Rule:
The Tailoring Rule may also affect sources that received Permits to Install before July 1, 2011 but did not begin construction by that date.
PSD permitting requirements will cover for the first time new construction projects that emit GHG emissions of at least 100,000 tons per year (tpy) even if they do not exceed the permitting thresholds for any other pollutant. Modifications at existing facilities that increase GHG emissions by at least 75,000 tpy will be subject to permitting requirements, even if they do not significantly increase emissions of any other pollutant.
Title V Permitting
Title V of the Clean Air Act will, for the first time, apply to sources based on their GHG emissions only. Facilities that emit at least 100,000 tpy CO2e and 100 tons of GHGs on a mass basis will be subject to Title V permitting requirements. In Michigan, these permits are known as Renewable Operating Permits (ROPs). Sources with fuel burning equipment (e.g. boilers, generators, ovens, and process heaters) and sources with large refrigeration units (e.g., warehouses, food processors) should review the GHG Permitting Guidance the AQD has developed to determine whether or not they will be affected by the Tailoring Rule.
Please contact Jim Ostrowski at (517) 241-8057 or at OstrowskiJ2@michigan.gov for questions regarding the GHG information on these pages.
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