The alternatives analysis under nonattainment NSR (and PSD?), presented at EUEC 2010

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Courtesy of Trinity Consultants

Outline

  • 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

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