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"EPA's Proposed GHG Tailoring Rule:" Within the next few months, EPA is poised to begin regulation of GHGs under an upcoming EPA regulation pertaining to light duty vehicle (LDV) emissions. EPA has indicated when this occurs that the current regulatory framework of the Clean Air Act and implementing regulations automatically triggers regulation of these pollutants under the Prevention of Significant Deterioration (PSD) and Title V operating permits programs. Since current emission thresholds triggering PSD and Title V permitting are very low for existing regulated pollutants, EPA is attempted to raise the PSD and Title V permitting thresholds for GHGs under the GHG Tailoring Rule, also scheduled for promulgation concurrently with the promulgation of the LDV Rule. This presentation provides an overview of the regulatory background for regulation of GHGs, the proposed Tailoring Rule, potential impacts of GHG regulation under the PSD and Title V program and uncertainties regarding implementation and timing. |
