Aug 23, 2018
EPA Clarifies “New” Unit for PAL Purposes
| EPA Clarifies “New” Unit for PAL Purposes
August 20, 2018 | Eric L. Hiser |
| Anna Marie Wood, Director, Air Quality Policy Division of the Office of Air Quality Planning and Standards issued a June 14, 2018 letter clarifying which units are treated as “new” for purposes of establishing baseline actual emissions (BAE) for a plantwide applicability limit (PAL). The letter was in response to an argument that “new” units should be based on the selected baseline period. EPA demurred, stating that a unit is only “new” for PAL purposes if the unit was built within two years prior to the current PAL action. This letter is important because a “new” unit uses its “potential to emit” (PTE) in lieu of actual emissions for determining BAE. |