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NSR Issues for Reform: Project Aggregation – Properly Defining the Project

Defining the “project” is crucial to completing any NSR/PSD applicability determination. At a facility with many operations, coincidentally timed projects, and production of intermediates, identifying a specific project, based on EPA guidance, is necessary for making a proper applicability or non-applicability determination. Despite leanings of the current administration, EPA relies most frequently on the criteria established in the 1993 3M Maplewood case to determine if multiple activities at a stationary source should be “aggregated” as a single project to prevent sham minor source permitting or improper PSD/NSR circumvention.

Our presenters look back to proposals made under the Bush administration to explore possible direction by the Trump EPA on updated and clarifying NSR aggregation guidance. In addition, we examine the 1993 3M Maplewood memo to review the implications of maintaining the status quo in applying this guidance going forward. Elements related to timing, intrinsic operational interdependence, and funding are reviewed. Topics include:

  • Overview of NSR project aggregation concepts
  • Aggregation under the 1993 3M Maplewood case
  • Bush-era NSR aggregation efforts
  • Implications of various guidance possibilities



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