NPRA suggests alternatives to EPA's proposed GHG regulations

Nick Snow
OGJ Washington Editor

WASHINGTON, DC, Dec. 29 -- The National Petrochemical & Refiners Association recommended three alternatives on Dec. 23 as it submitted comments to the US Environmental Protection Agency opposing EPA’s proposed greenhouse gas regulations under the Clean Air Act.

“The path to [GHG regulation under the CAA] that EPA has chosen is difficult, uncertain, and unnecessarily risky in these troubling economic times. The Tailoring Rule that is the subject of these comments is doomed to failure,” NPRA said.

“Fortunately, the timing, manner, and content of EPA’s overall approach to regulating GHGs under the CAA [are] firmly with the agency’s control,” NPRA said, adding, “Our comments outline ways in which EPA could proceed down alternative pathways that provide more sensible regulation without [resorting] to extraordinary administrative law principles that cannot be applied in these circumstances.”

EPA issued the proposed rulemaking, “Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule,” on Oct. 27. It would require facilities emitting more than 25,000 tons/year of GHGs to obtain permits demonstrating that they are using best practices and technologies to minimize GHG emissions, according to information at the agency’s web site.

It also proposes new GHG emissions thresholds defining when CAA permits under the New Source Review and Title V operating permits programs would be required for new or existing industrial plants. The proposed thresholds would “tailor” the requirement so it would not apply to small farms, restaurants, and other small businesses while covering refineries, power plants, and other large installations that EPA said are responsible for nearly 70% of the nation’s total GHG emissions from stationary sources.

Endangerment finding
The proposed rulemaking’s significance increased with EPA’s Dec. 7 announcement that it had determined that six GHGs pose significant dangers to human health and are potentially subject to CAA regulation.

NPRA recommended that EPA interpret that the CAA’s PSD provision be triggered only after a National Ambient Air Quality Standard is established for a pollutant. “Under this interpretation, which is fully consistent with the CAA and EPA’s regulations, the [Section] 202 Rule would result in GHGs only being subject to Best Available Control Technology requirements if a source otherwise triggers PSD for a criteria pollutant,” it said.

The agency also could delay issuing the 202 rule until it and the states are better prepared to address GHG permitting, NPRA continued. “EPA could use this time to pursue streamlining of PSD and Title V requirements on an aggressive time scale to avert the large economic impacts that the agency indicates Congress did not intend,” it said.

NPRA said EPA also could specify that under the 202 rule, the date when GHGs are considered subject to “actual control” would be when vehicle manufacturers must comply with an attribute-based standard for the 2012 model year. “This would avoid an imminent PSD trigger for stationary sources and give states and EPA more time to address GHG permitting issues,” the association said in its comments.

Contact Nick Snow at

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