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Oregon’s Implementation of the Area Source NESHAPs

Oregon’s Implementation of the Area Source NESHAPs. National Association of Clean Air Agencies Spring Membership Meeting May 17-19, 2010. Andy Ginsburg, Administrator Oregon Department of Environmental Quality. Why Implement the Area Source NESHAPs?. Protect public health

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Oregon’s Implementation of the Area Source NESHAPs

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  1. Oregon’s Implementation of the Area Source NESHAPs National Association of Clean Air Agencies Spring Membership Meeting May 17-19, 2010 Andy Ginsburg, Administrator Oregon Department of Environmental Quality

  2. Why Implement the Area Source NESHAPs? • Protect public health • Increase compliance • Provide assistance to • affected businesses • Ability to be flexible and responsive • Opportunity to prevent need for enforcement

  3. What Are The Barriers? • Many previously unpermitted sources • Many are small businesses • Revenue and staffing • Quality of some of the NESHAPs

  4. How is Oregon Implementing the Area Source NESHAPs? • Adoption triggers state (non-Title V) permit requirement • Simple and Standard Permits • Apply to individual sources • General Permits • Apply to multiple or categories of sources • Registration • Alternative to permitting

  5. New General ACDP Fee Classes for Area Source NESHAPs

  6. Fee Class Assignments for Area Source NESHAPs

  7. Registration –Alternative to Permitting • Incentive to go beyond compliance • Auto body shops - EcoBiz • Dry Cleaner certification

  8. www.ecobiz.org

  9. Lessons Learned • Anticipate business association objections • Don’t overestimate revenue • Simplify and clarify • Some work is unfunded • Push back at permitting stage • Keep legislators informed

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