Clean Air Act—Flexible Plantwide GHG Permits

摘要

As companies operating major stationary sources of GHG emissions work their way through the Clean Air Act New Source Review process in obtaining CAA permits, including application of the Best Available Control Technology ("BACT") for GHG, those familiar with the CAA PAL permits, or "Plantwide Applicability Limits" are probably considering the flexibility PALs might provide in complying with permitted emission limits. Not so fast.