Brownstein Client Alert, October 5, 2009
In the past few months, EPA has proposed or finalized regulations establishing GHGs as a pollutant covered by the Clean Air Act (CAA), regulating emissions from stationary sources and automobiles, and requiring large stationary sources to report their GHG emissions annually. The most recently-proposed regulations establish new GHG emission thresholds for Prevention of Significant Deterioration (PSD) and Title V operating permits for large new or existing industrial facilities. While Congress debates climate-change legislation, EPA has been moving forward with GHG regulations pursuant to its existing Clean Air Act authority. To read more, please click above.