Post on 18-Jan-2016
MassDEP Response to EPA GHG Initiatives
SIP Steering CommitteeJanuary 13, 2011
Marc Wolman
MassDEP Response to EPA GHGInitiatives
• Reporting Rule• PSD• Title V • BACT Guidance
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MassDEP Response to EPA Mandatory GHG Reporting Rule
• EPA does not delegate to states• MassDEP implemented 310 CMR 7.71
“Reporting of Greenhouse Gas Emissions” independently from federal regulation
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MassDEP Response to GHG Tailoring for PSD
• No response necessary, since EPA implements PSD in Massachusetts
• MassDEP considering adding GHG tailoring thresholds to 310 CMR 7.54 “Large Combustion Emission Units
• Need explicit provisions for capping GHG emissions to avoid PSD, Title V
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MassDEP Response to GHG Tailoring for Title V
• MassDEP preparing amendment to 310 CMR 7.00, Appendix C, (Title V Operating Permits)
• Major GHG-emitting Facility without OP must submit complete OP application, or receive final approval of OP-avoidance emissions cap by July 1, 2012
• Need explicit provisions for capping GHG emissions to avoid PSD, Title V
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MassDEP Response to EPA BACT Guidance
• EPA BACT Guidance applies to PSD review, by EPA in Massachusetts
• EPA Guidance focuses on energy efficiency• MassDEP Plan Application Form revisions will
include energy efficiency questionnaire• MassDEP considering guidance on appropriate
threshold for minor source GHG review
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