Support Facilities Revisited

摘要

As they say, the only thing that is certain is that you can never be certain of anything. So, just when I started to think that there is at least one fairly consistent interpretation of the new source review (NSR) regulations out there, I ran into a situation where a state agency interpretation of a basic NSR definition differs from all prior EPA interpretations. Since the state interpretation is more stringent than EPA interpretations, EPA, of course, is not objecting to the new approach. This is an extraordinarily detailed article on a usually minor aspect of what constitutes a stationary source. However, this example illustrates a number of the problems and frustrations affecting air pollution permitting, especially NSR permitting, so it needs to be examined in more detail. It also indicates how an agency interpretation can come out of nowhere, and yet it is nearly impossible for a source needing a permit to oppose. Finally, it shows the far-reaching effect a policy decision (or new interpretation) can have on a source. Unfortunately, I feel that the situation described here also provides a fresh reminder that lower labor costs aren't the only reason the United States is losing manufacturing jobs to other countries. [NOTE: Throughout this series, reference is made to NSR-related documents contained in the 5-volume NSR Guidance Notebook and other guidance. Documents from the Notebook are referenced by a unique document number, e.g., Item 5.32. Other documents are indicated by a letter or number-letter combination (M or 3Q) and are listed at the end of this article.].