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Greenhouse Gas Tailoring Rule

Greenhouse Gas Tailoring Rule. aka GHG Permitting Rule. August 4, 2010. Brief History or How We Got to This Point. GHG Mandatory Reporting Rule – Oct 09 EPA made Endangerment Finding – Dec 09 Mobile Source GHG Rule – Apr 10

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Greenhouse Gas Tailoring Rule

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  1. Greenhouse Gas Tailoring Rule aka GHG Permitting Rule August 4, 2010

  2. Brief History orHow We Got to This Point • GHG Mandatory Reporting Rule – Oct 09 • EPA made Endangerment Finding – Dec 09 • Mobile Source GHG Rule – Apr 10 • First national rule limiting GHG emissions from cars and light trucks • Model year 2012 vehicles (Jan 2, 2011) • Triggers permitting requirements for GHG

  3. What Are Greenhouse Gases? • Carbon dioxide (CO2) • Methane (CH4) • Nitrous oxide (N2O) • Hydrofluorocarbons (HFCs) • Perfluorocarbons (PFCs) • Sulfur hexafluoride (SF6)

  4. CO2 Equivalent • All GHGs have an Global Warming Potential (GWP) • GWP ranges from 1 to 23,900 • Example: • Methane GWP is 21 • If you emit 5,000 tons of Methane (CH4), • Multiply by GWP of 21 • CO2eemissions of 105,000 tons

  5. Greenhouse GasesGlobal Warming Potential • Carbon dioxide (CO2) (GWP=1) • Methane (CH4) (GWP=21) • Nitrous oxide (N2O) (GWP=310) • Hydrofluorocarbons (HFCs) (GWP=12 to 11,700) • Perfluorocarbons (PFCs) (GWP= 6,500 to 9,200) • Sulfur hexafluoride (SF6) (GWP=23,900)

  6. Impact on Permitting • Current permitting thresholds: • PSD: • 250 tpy • 100 tpy for listed sources • Title V: • 100 tpy • EPA estimated 6 million sources would need Title V permits & 82,000 PSD permit actions per year would be needed

  7. “Tailoring Rule” • Finalized June 3, 2010 • “Tailoring” the applicability criteria for air permits for GHG • Without: • Current criteria (100/250 tpy) applies • Huge numbers of permits required • Overwhelms resources of states • Severely impairs the functioning of permit programs • EPA estimates 15,550 Title V sources & 1,600 PSD actions under Tailoring Rule

  8. Operating Permits Burden Reductions Without the Tailoring Rule With the Tailoring Rule 6 million sources would have needed operating permits • Only 15,550 sources will need operating permits • 15,000sources already haveoperating permits • Only 550 more sources will be subject to operating permitting for GHGs alone – but not until more than a year from now. 8

  9. PSD Permitting Burden Reductions Without the Tailoring Rule With the Tailoring Rule • Only 1,600 permitting actions per year will need to address GHG • 82,000 permitting actions per year would need to address GHGs • 700 permitting actions that would already occur will need to address GHGs • 900 more permitting actions will occur to address GHGs – but not until more than a year from now 9

  10. Phased Approach • PHASE 1 – Effective Jan 2, 2011 • “Anyway” sources (for existing pollutants) • Applies to any existing source in PSD permitting program modifying by 75,000 tpy CO2e • PHASE 2 – Effective July 1, 2011 • Applies to any new or existing source of CO2e over 100,000 tpy (75,000 tpy for modifications)

  11. Phase-In Step 3 • EPA rulemaking nlt July 1, 2012 • Consider inclusion of additional sources • Would be effective July 1, 2013 • EPA says not below 50,000 tpy (for at least 6 yrs) • EPA to explore wide range of streamlining options • Possibly permanently exclude certain sources from PSD, Title V or both

  12. What About the Future? • No smaller sources before April 30, 2016 or later • EPA to study issue within 5 years looking at admin burden if small sources pulled into program • Additional rulemaking nlt April 30, 2016

  13. Permitting Steps under the Tailoring Rule • Step 1: Source already subject to PSD “anyway” (tpy CO2e) New source: NA Modification: 75,000 • Step 2: Sources already subject to PSD (tpy CO2e)New source: 100,000Modification: 75,000 • Step 3: Implementation of potential additional phase-in and streamlining options • 5-year study: To examine GHG permitting for smaller sources • Implementation of rule based on 5-year study 2011 2012 2013 2014 2015 2016 Study Complete

  14. What is Utah Doing? • Reviewing federal program • Existing statutes appear to allow us to permit GHG • Reviewing state rules for necessary changes • Stakeholder process underway • Anticipated workload

  15. Tight Timeline • Should be in place by Jan 2, 2011 • Info briefing to AQB at August meeting • Proposed rules to AQB at September meeting • Proposed final approval of rules to AQB at December meeting • If no changes, effective Jan 1, 2011

  16. Without Rule Changes • Existing applicability criteria applies (huge numbers of permits required) • EPA would issue SIP Call and then administer the GHG part of the program (with the new thresholds) under a FIP • Timing gap would expose small sources to permitting requirements

  17. Contacts • Title V – Brandy Cannon • 801-536-4070 • bcannon@utah.gov • NSR – Camron Harry • 801-536-4232 • caharry@utah.gov • General – Regg Olsen • 801-536-4165 • rdolsen@utah.gov

  18. QUESTIONS?

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