The Bump in the Road: Air Permitting of Thermal Treatment and Renewable Energy/Fuels Projects

摘要

Recently promulgated regulations promote environmentally-beneficial programs such as renewable portfolio standards, sustainability practices, and Greenhouse Gas (GHG) emission reductions. As energy costs increase, waste-to energy/fuel projects have become more popular. Project proponents have greater access to government support and funding opportunities than in the past. Nevertheless, air permitting regulations can be the "bump" in the road that can derail the "greenest" project. Some alternative energy projects combust municipal solid waste (MSW), municipal biosolids and/or greenwaste directly in fluidized beds and gasifiers. Other alternative energy projects generate municipal digester gas, landfill gas, and/or manure digester gas and combust these gases in internal combustion engines, boilers, fuel cells, and microturbines. New Source Review (NSR) can be a major barrier to these projects because of Best Available Control Technology (BACT) and emission offset requirements. Air regulations for combustion sources are increasingly strict and generally do not account for differences between renewable gaseous fuels and natural gas. Offset requirements can be challenging due to high cost and low availability and offset regulations do not account for the emission reduction benefits of these projects compared to traditional management of these feedstocks. We will examine barriers that waste-to-energy/fuel projects face in obtaining air permits, particularly in California where air regulations are among the toughest in the world and environmental justice is a major consideration. We present real-world examples of air permitting and regulatory challenges facing waste-to-energy/fuel projects, suggest ways to minimize these challenges, and identify policies that may make permitting these important projects more feasible.