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NSR Reform: Pre-Change Projected Actual Emissions Assessments and Post-Change Emissions Monitoring and Reporting

During this first in a series of four webinars on complex New Source Review Reform issues, Trinity President Jay Hofmann and Managing Director Mike Remsberg examine policy and guidance for pre-change projected actual emissions (PAE) assessments and monitored post-change actual emissions, including when “excluded emissions” are considered in the pre-change or post-change  assessments. The discussion addresses existing rule language, historical guidance provided by EPA, examples of how the rule and guidance have been interpreted, court cases that have shaped enforcement, and the EPA Administrator's December 7, 2017, memorandum addressing the agency's current enforcement position.   

The presentation provides viewers with a greater understanding on how to incorporate these issues into site modification plans, what bases for negotiation they may have with regulators, and how to engage in the regulatory/policy development process on this issue. 

 


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