Impending GHG Emission Reduction Requirements EUCI June 17, 2010. PRESENTED BY Peter Glaser Troutman Sanders LLP 401 9 th Street, NW Suite 1000 Washington, DC 20004 202.274.2950 www.troutmansanders.com. Potential GHG Regulation. Congress or EPA or Both?.
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Impending GHG Emission Reduction RequirementsEUCIJune 17, 2010
Troutman Sanders LLP
401 9th Street, NW
Washington, DC 20004
→ Neither provision fully developed
Endangerment Finding Litigation
Johnson Memorandum Reconsideration
GHG BACT Guidance
- 1/2/11: Sources subject to PSD “anyway” will be required to do GHG BACT if increase emissions by 75,000 tons per year
- 7/1/11: New sources above 100,000 tpy and existing sources that increase emissions by 75,000 subject to PSD
- EPA will do future rulemaking and future study to determine whether lower emitting sources will be regulated and how, but commits that no source below 50,000 tpy will be regulated for six years