An NSR Legal Update

摘要

In order to navigate the Clean Air Act, it is just as important to follow court rulings as it is to follow the release of new regulations. The recent Supreme Court ruling on the Cross State Air Pollution Rule (CSAPR) was widely reported, but several other recent decisions also directly impact the utility industry. These rulings affect a wider audience than just CSAPR facilities but were less publicized. Additionally, these rulings are tied up in that most confusing of New Source Review (NSR) issues: when does a modification require a Prevention of Significant Deterioration (PSD) pre-construction permit?