If EPA considers CO2 and other GHGs as pollutants under the Clean Air Act and allows states to regulate motor vehicles then any emission of these gases will have to follow the strict controls set by the Prevention of Significant Deterioration (PSD) program.
If CO2 becomes a regulated CAA pollutant, then it affects not only motor vehicles but also has an effect on “stationary sources”. Any new “major” stationary sources that can emit at least 100 tons per year of any regulated air pollutant will first have to obtain a PSD permit and require complying with the CO2 Best Available Control Technology (BACT). Another factor is that any modifications to existing “major” stationary sources that might increase their CO2 emissions, even by a small amount, must obtain a permit and must comply with the BACT requirement.
Effect on stationary sources -
If CO2 is regulated under the CAA, then stationary sources that have never come under the PSD program will have to obtain permit and comply with the BACT requirement. E.g., buildings more than 100000 sq ft that uses heating oil and natural gas, and other relatively small users of natural gas such as commercial kitchens, businesses that use CO2 as their raw material, office buildings and apartment complexes, sports arenas, enclosed malls, Universities, restaurants, hospitals etc., which emit very small amounts of traditional air pollutants and will be forced to come under the PSD regulation.
Administrative bottlenecks –
A circumstance, where any modifications to existing or new investments in infrastructure, requiring new permits will tend put a lot of pressure on the administrative department of the EPA. The processing of permits is expensive, time consuming, and also burdensome. An influx of applications for new permits will create backlogs as the EPA does not have the infrastructure in place to handle processing of large pools of application permits.... [continues]
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