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Greenhouse Gas Tailoring Rule. aka GHG Permitting Rule. August 4, 2010. Brief History or How We Got to This Point. GHG Mandatory Reporting Rule – Oct 09 EPA made Endangerment Finding – Dec 09 Mobile Source GHG Rule – Apr 10

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greenhouse gas tailoring rule

Greenhouse Gas Tailoring Rule

aka

GHG Permitting Rule

August 4, 2010

brief history or how we got to this point
Brief History orHow We Got to This Point
  • GHG Mandatory Reporting Rule – Oct 09
  • EPA made Endangerment Finding – Dec 09
  • Mobile Source GHG Rule – Apr 10
    • First national rule limiting GHG emissions from cars and light trucks
    • Model year 2012 vehicles (Jan 2, 2011)
    • Triggers permitting requirements for GHG
what are greenhouse gases
What Are Greenhouse Gases?
  • Carbon dioxide (CO2)
  • Methane (CH4)
  • Nitrous oxide (N2O)
  • Hydrofluorocarbons (HFCs)
  • Perfluorocarbons (PFCs)
  • Sulfur hexafluoride (SF6)
co 2 equivalent
CO2 Equivalent
  • All GHGs have an Global Warming Potential (GWP)
  • GWP ranges from 1 to 23,900
  • Example:
    • Methane GWP is 21
    • If you emit 5,000 tons of Methane (CH4),
    • Multiply by GWP of 21
    • CO2eemissions of 105,000 tons
greenhouse gases global warming potential
Greenhouse GasesGlobal Warming Potential
  • Carbon dioxide (CO2) (GWP=1)
  • Methane (CH4) (GWP=21)
  • Nitrous oxide (N2O) (GWP=310)
  • Hydrofluorocarbons (HFCs) (GWP=12 to 11,700)
  • Perfluorocarbons (PFCs) (GWP= 6,500 to 9,200)
  • Sulfur hexafluoride (SF6) (GWP=23,900)
impact on permitting
Impact on Permitting
  • Current permitting thresholds:
    • PSD:
      • 250 tpy
      • 100 tpy for listed sources
    • Title V:
      • 100 tpy
  • EPA estimated 6 million sources would need Title V permits & 82,000 PSD permit actions per year would be needed
tailoring rule
“Tailoring Rule”
  • Finalized June 3, 2010
  • “Tailoring” the applicability criteria for air permits for GHG
  • Without:
    • Current criteria (100/250 tpy) applies
    • Huge numbers of permits required
    • Overwhelms resources of states
    • Severely impairs the functioning of permit programs
  • EPA estimates 15,550 Title V sources & 1,600 PSD actions under Tailoring Rule
slide8

Operating Permits Burden Reductions

Without the Tailoring Rule

With the Tailoring Rule

6 million sources would have needed operating permits

  • Only 15,550 sources will need operating permits
  • 15,000sources already haveoperating permits
  • Only 550 more sources will be subject to operating permitting for GHGs alone – but not until more than a year from now.

8

psd permitting burden reductions
PSD Permitting Burden Reductions

Without the Tailoring Rule

With the Tailoring Rule

  • Only 1,600 permitting actions per year will need to address GHG
  • 82,000 permitting actions per year would need to address GHGs
  • 700 permitting actions that would already occur will need to address GHGs
  • 900 more permitting actions will occur to address GHGs – but not until more than a year from now

9

phased approach
Phased Approach
  • PHASE 1 – Effective Jan 2, 2011
    • “Anyway” sources (for existing pollutants)
    • Applies to any existing source in PSD permitting program modifying by 75,000 tpy CO2e
  • PHASE 2 – Effective July 1, 2011
    • Applies to any new or existing source of CO2e over 100,000 tpy (75,000 tpy for modifications)
phase in step 3
Phase-In Step 3
  • EPA rulemaking nlt July 1, 2012
    • Consider inclusion of additional sources
    • Would be effective July 1, 2013
    • EPA says not below 50,000 tpy (for at least 6 yrs)
  • EPA to explore wide range of streamlining options
  • Possibly permanently exclude certain sources from PSD, Title V or both
what about the future
What About the Future?
  • No smaller sources before April 30, 2016 or later
  • EPA to study issue within 5 years looking at admin burden if small sources pulled into program
  • Additional rulemaking nlt April 30, 2016
permitting steps under the tailoring rule
Permitting Steps under the Tailoring Rule
  • Step 1: Source already subject to PSD “anyway” (tpy CO2e) New source: NA Modification: 75,000
  • Step 2: Sources already subject to PSD (tpy CO2e)New source: 100,000Modification: 75,000
  • Step 3: Implementation of potential additional phase-in and streamlining options
  • 5-year study: To examine GHG permitting for smaller sources
  • Implementation of rule based on 5-year study

2011

2012

2013

2014

2015

2016

Study Complete

what is utah doing
What is Utah Doing?
  • Reviewing federal program
  • Existing statutes appear to allow us to permit GHG
  • Reviewing state rules for necessary changes
  • Stakeholder process underway
  • Anticipated workload
tight timeline
Tight Timeline
  • Should be in place by Jan 2, 2011
  • Info briefing to AQB at August meeting
  • Proposed rules to AQB at September meeting
  • Proposed final approval of rules to AQB at December meeting
  • If no changes, effective Jan 1, 2011
without rule changes
Without Rule Changes
  • Existing applicability criteria applies (huge numbers of permits required)
  • EPA would issue SIP Call and then administer the GHG part of the program (with the new thresholds) under a FIP
  • Timing gap would expose small sources to permitting requirements
contacts
Contacts
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