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

During this first in a series of four monthly 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 will address 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.   

Participants will gain a greater understanding of how to incorporate these issues into their modification plans, what bases for negotiation they may have with regulators, and how to engage in the regulatory/policy development process on this issue. 

This presentation is intended for facility and corporate environmental staff at industrial companies, and environmental attorneys, who are involved in NSR permitting.


Webinar topics
  • Background and review of projected actual emissions and the related NSR applicability procedures (including how projections are made, “excluded” emissions associated with demand growth, etc., and post project monitoring and recordkeeping requirements)  
  • A review of the U.S. EPA’s current enforcement stance on “second guessing” NSR emissions projections
  • A review of the court cases and regulatory interpretation of how/when emissions projections satisfy the regulatory requirements
  • An assessment of possible changes in methods or guidance that could bring increased clarity and consistency among the U.S. EPA regions and local permitting authorities
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Partner courses

NSR Issues for Reform: Accounting for Project-Related Emissions Reductions at the Project Assessment Level (Step 1)

During this second webinar in a four-part series, Trinity senior NSR experts will discuss the issue of accounting for project-related emission reductions at the project assessment level ("Step 1") including the regulatory and legal background, the difficulties and ambiguities under current rule or policy, possible approaches to reform, and their associated implications for industry. 

This presentation is intended for facility and corporate environmental staff at industrial companies, and environmental attorneys, who are involved in NSR permitting. Attendance will help environmental professionals who are responsible for major source permitting for their companies to develop a useful framework from which to monitor future developments. 

NSR Issues for Reform: What Qualifies for the Routine Maintenance, Repair, & Replacement Exclusion

During this third webinar in a four-part series, Trinity senior NSR experts will discuss the issue of activities that qualify under the routine maintenance, repair, and replacement exclusion including the regulatory and legal background, the difficulties and ambiguities under current rule or policy, possible approaches to reform, and their associated implications for industry. Attendance will help environmental professionals who are responsible for major source permitting for their companies to develop a useful framework from which to monitor future developments. 

This presentation is intended for facility and corporate environmental staff at industrial companies, and environmental attorneys, who are involved in NSR permitting.

NSR Issues for Reform: Addressing Emissions from Debottlenecking Projects

During this final webinar in a four-part series, Trinity senior NSR experts will discuss the issue of NSR applicability for complex projects that impact emissions from both modified and unmodified existing emissions units (i.e., "debottlenecking" projects) including the regulatory and legal background, the difficulties and ambiguities under current rule or policy, possible approaches to reform, and their associated implications for industry. Attendance will help environmental professionals who are responsible for major source permitting for their companies to develop a useful framework from which to monitor future developments. 

This presentation is intended for facility and corporate environmental staff at industrial companies, and environmental attorneys who are involved in NSR permitting.