The U.S. EPA has recently issued several memos discussing New Source Review (NSR) and how to account for project emissions when conducting Prevention of Significant Deterioration (PSD) analyses. How these calculations are done-and ensuring they are done correctly-can mean the difference between getting a permit and being subject to unanticipated changes in project scope and schedule. But getting the calculations "correct" is not a clear-cut process-there often can be varying approaches to performing a PSD analysis strategically, and these can determine whether you have operational flexibility once your project is implemented or you are at risk for compliance issues.

EPA's recent memos regarding actual-to-projected-actual applicability tests (December 7, 2017), Project Emissions Accounting (March 13, 2018), and final action regarding Project Aggregation (November 15, 2018) provide options to facilities that are looking to expand or modify their operations. For example, correctly and strategically implementing debottlenecking, demand growth, and "could have accommodated" adjustments to project emission calculations (for turbine upgrade projects, for example) can easily determine not just whether PSD is triggered at your facility, but also if compliance risk with the modified permit is minimized and authorized operational flexibility is maximized. Furthermore, correctly applying these analyses to your individual projects can make it easier to demonstrate compliance in future Actual Emissions Reports.

Trinity Consultants prides itself on being national experts in performing these complicated air permitting PSD analyses, preparing robust emissions calculations, and developing permit applications that streamline the permitting process and ease future compliance burdens. We are able to offer this strategic service because of our deep understanding of the regulations and our daily experience working with PSD, whereas a facility may evaluate PSD applicability only every few years for new projects. Both nationally and throughout the state of Florida, Trinity Consultants works closely with state regulators to ensure that these analyses are prepared correctly, while also being mindful of our clients' economic, operational, and environmental interests. Please contact Michael Ballenger at mballenger@trinityconsultants.com or (407) 982-2891 in our Orlando office if you are interested in discussing PSD considerations at your facility.