Last Wednesday, the Environmental Protection Agency (“EPA”), published a set of guidance documents to assist state authorities and industry applicants with the Clean Air Act “prevention of significant deterioration” (PSD) and Title V permitting for sources of greenhouse gas emissions (GHGs). EPA has declared that GHGs are a danger to human health and the environment and must be regulated under the Clean Air Act. With the guidance, EPA seeks to reassure major emitters (the first group to be regulated) that impending regulation will not be too burdensome and that permitting decisions will take cost and technical feasibility into account. The… Read more