White Paper: Greenhouse Gas Permitting Issues and Approaches for Addressing Greenhouse Gas Emissions

Addressing Climate Change: Emerging Policies, Strategies, and Technological Solutions
Oak Brook, IL
September 9-10, 2015

Cassandra B. Drotman, Raymond H. Huff, SCS Engineers, Long Beach, California, and Patrick S. Sullivan, SCS Engineers, Sacramento, California

Summary:
With the instability of GHG regulations over the past few years, facilities have been struggling to keep up with the ever-changing framework. Under the CAA, GHG emission reporting and regulations have been implemented, suspended, and revoked, while at the state and local jurisdictional level GHG rules and requirements have been following federal directions. The constant change for existing permitted facilities has been challenging and for new facilities which have briefly been required to determine if they are affected or not has been even more challenging. On top of all of the GHG regulation and permitting issues, biogenic facilities such as landfills, have had an even more difficult time with the biogenic deferral and how it impacts their existing facilities.

The proposed NSPS MSW landfill rule is also going to significantly modify the operations and GHG emission reductions at landfills. If the proposed rule is adopted, it will switch the focus from NMOC reductions to limiting CH4, a major source of GHGs, it is expected that approximately 1,000 landfills will be impacted. As the Supreme Court decided that GHG emissions definition of a major source could not be tailored, CH4 emissions would not be able to tailor be tailored either. As one of the main reportable GHG, any increase CH4 emissions would be considered major under Title V and PSD forcing facilities to undergo NSR for facilities. The proposed rule only adds confusion to the regulating GHGs for landfills. Only the test of time will show how GHGs are end added to the current regulatory framework under the CAA.

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