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. 

Additional information on the discussion topics will be posted approximately one month prior to the webinar, and as needed, in order to reflect recent developments.

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


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May 22, 2018 -- Online
12:00 PM - 1:00 PM CST/CDT

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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.

Mar 27, 2018 -- Online