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     NAQQS Permitting Gridlock
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NAAQS Permitting Problems and Solutions


EPA should address the rapidly-developing air permitting gridlock by adopting more flexible policies and allow use of more realistic emissions data and modeling tools.


Background:

Every five years, EPA must decide whether the National Ambient Air Quality Standards (NAAQS) are sufficiently protective of public health. Recently, EPA has systematically tightened the NAAQS for particulate matter (PM), sulfur dioxide, nitrogen oxides and ozone. Traditionally, the focus of the program has been on states developing plans to slowly improve air quality in non-attainment areas (usually cities) to meet the NAAQS. However, since the NAAQS are effective immediately, facilities contemplating expansions or modifications that trigger a permitting review must demonstrate that emissions from the plant when combined with background air quality do not exceed the applicable NAAQS standard in order to obtain a permit.


Permit Stalemate:

With NAAQS having dropped closer to background levels, it is becoming more difficult to “pass the test” and get an approved permit. To prevent further ratcheting, EPA should not lower standards further until current standards are fully implemented and met as air quality will continue to improve under current programs. The decline of permit submittals to states is a strong indication of this growing problem.

The inability to permit a project hurts the competitiveness of the facility, harms product development and innovation and can thwart environmentally-beneficial projects. Local communities will miss out on new jobs and economic growth while industry sectors face the risk of becoming uncompetitive in the global marketplace of forest products.


New Permitting Policies Could Help Alleviate the Problem:

The challenges with the ever-tighter NAAQS are exacerbated by a lack of (or inappropriate) emission measurement methods, poor estimates of emissions, use of unrealistic air dispersion models and several rigid permitting policies. AF&PA has provided EPA several suggestions, including lowering fugitive PM emissions, acknowledging intermittent sources and using better receptor locations. EPA’s own recognition of the advantages of probabilistic tools should be incorporated into the permitting guidance to avoid over-estimates. In addition, EPA should defer site-specific photo-chemical modeling for the latest ozone NAAQS until extensive validation is completed. Finally, EPA’s modeling guidance should be continually modernized to embrace new tools quickly and generally adopt more flexible permitting policies.


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