EPA's Combustion-Related MACTs: Yes, It Really Is This Complicated!

摘要

The United States Environmental Protection Agency promulgated five rules in 2004 and 2005 regulating emissions of hazardous air pollutants from combustion-related sources. Generally, existing sources must comply with these rules three years after their promulgation, i.e., either 2007 or 2008, and sources should be taking steps toward complying with them now. While all of these rules are similar on the surface, they differ widely on important components such as the size of facilities that are regulated, the HAPs that are limited, and the types of pollution control devices EPA expects a facility will use. In addition, two of the rules implement a relatively complicated and controversial risk-based standard for several "threshold" pollutants. Moreover, four of the rules have been either revised or challenged in court, or both, and some are still in flux. This paper will compare and contrast the five rules, discuss their current status, and offer insight into their futures.