MassDEP Response to EPA GHG Initiatives

SIP Steering CommitteeJanuary 13, 2011

Marc Wolman

MassDEP Response to EPA GHGInitiatives

• Reporting Rule• PSD• Title V • BACT Guidance

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MassDEP Response to EPA Mandatory GHG Reporting Rule

• EPA does not delegate to states• MassDEP implemented 310 CMR 7.71

“Reporting of Greenhouse Gas Emissions” independently from federal regulation

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MassDEP Response to GHG Tailoring for PSD

• No response necessary, since EPA implements PSD in Massachusetts

• MassDEP considering adding GHG tailoring thresholds to 310 CMR 7.54 “Large Combustion Emission Units

• Need explicit provisions for capping GHG emissions to avoid PSD, Title V

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MassDEP Response to GHG Tailoring for Title V

• MassDEP preparing amendment to 310 CMR 7.00, Appendix C, (Title V Operating Permits)

• Major GHG-emitting Facility without OP must submit complete OP application, or receive final approval of OP-avoidance emissions cap by July 1, 2012

• Need explicit provisions for capping GHG emissions to avoid PSD, Title V

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MassDEP Response to EPA BACT Guidance

• EPA BACT Guidance applies to PSD review, by EPA in Massachusetts

• EPA Guidance focuses on energy efficiency• MassDEP Plan Application Form revisions will

include energy efficiency questionnaire• MassDEP considering guidance on appropriate

threshold for minor source GHG review

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