Netting Under the NSR Reform Rules—Part 3: When 'Actual' Does Not Mean 'Actual'

摘要

In this article, we return to the topic of "Netting Under the NSR Reform Rules" that we discussed at length in 2004 in Volume 14, Issues 1 and 2 of the Air Pollution Consultant. The two-part series explained the procedures used for calculating "net emissions increases" ("netting") under the prevention of significant deterioration (PSD) or nonattainment major new source review (NSR) programs. In this article, in light of more recent guidance, we revisit the netting issue.