Comments on: EPA’s Permitting Guidance for Greenhouse Gases – Does It Endanger Coal? http://www.globalwarming.org/2010/11/11/can-best-available-control-technology-bact-require-fuel-switching/ Climate Change News & Analysis Wed, 12 Dec 2012 14:44:39 +0000 hourly 1 http://wordpress.org/?v= By: Bobhttp://www.globalwarming.org/2010/11/11/can-best-available-control-technology-bact-require-fuel-switching/comment-page-1/#comment-46457 Bob Mon, 22 Nov 2010 11:07:35 +0000 http://www.globalwarming.org/?p=6455#comment-46457 I read the guidance as allowing the permitting authority (EPA or state) to have great latitude in how they interpret BACT. Although BACT allows you to include and consider the cost of the emissions reduction, the $/ton of pollutant removed level that allows selection of a less expensive, and potentially more polluting, technology varies from state to state and from permitting engineer to permitting engineer. This rule completely allows BACT to be determined by whim of the permit writer. Another cute piece of the rule: The GHG reporting rule prohibits a source that uses biogenic methane (e.g., landfill gas) to produce usuable energy from reporting the CO2 from the gas. The reporting floor is 25,000 metric tons/year (~55,100 short tons). The Tailoring Rule requires permitting for 75,000 short tons/year and requires inclusion of methane from biogenic sources. If the angency were trying to make this substantially confusing and difficult, they certainly have succeeded. PS. Where in the CAA does one find a major source defined as 75,000 tons/year? I believe the EPA is making stuff up as they go along, and not very consistently. I read the guidance as allowing the permitting authority (EPA or state) to have great latitude in how they interpret BACT. Although BACT allows you to include and consider the cost of the emissions reduction, the $/ton of pollutant removed level that allows selection of a less expensive, and potentially more polluting, technology varies from state to state and from permitting engineer to permitting engineer. This rule completely allows BACT to be determined by whim of the permit writer.

Another cute piece of the rule: The GHG reporting rule prohibits a source that uses biogenic methane (e.g., landfill gas) to produce usuable energy from reporting the CO2 from the gas. The reporting floor is 25,000 metric tons/year (~55,100 short tons). The Tailoring Rule requires permitting for 75,000 short tons/year and requires inclusion of methane from biogenic sources. If the angency were trying to make this substantially confusing and difficult, they certainly have succeeded.

PS. Where in the CAA does one find a major source defined as 75,000 tons/year? I believe the EPA is making stuff up as they go along, and not very consistently.

]]>