- Why does it matter?
- Statutory and Regulatory Basis
- Nonattainment NSR Examples
- PSD Examples
- Best Practices
Why does it matter?
- Most requirements for an NNSR or PSD permit have bounds
- Demonstrate acceptable air quality impacts (PSD)
- Offset adequate emissions (NNSR)
- Show usage of the best control strategy to achieve a low emission rate (both)
- Show other sources in state are in compliance (NNSR)
- In contrast, the alternatives analysis is essentially boundless, and the determination can turn on highly subjective comparisons
- The “no build” option is often considered