In a February 22 letter to members of the US Senate, EPA Administrator Lisa Jackson has proposed a rough schedule for phasing in of regulatory control of greenhouse gas emissions from stationary sources.
Ms. Jackson’s letter (which can be read in its entirety here) anticipates that permit requirements for control of greenhouse gas emissions from large stationary sources will appear in 2011, requiring first those facilities already subject to permitting as major sources of priority or hazardous air pollutants to address greenhouse gas emissions in their permit applications. Other “large” sources (i.e., those emitting more than 25,000 tons of carbon dioxide and other greenhouse gases per year) will follow, though the Administrator expressed an expectation that the threshold for permitting through 2013 will be substantially higher than the original 25,000 ton level. Permitting for smaller sources is not anticipated prior to the year 2016, according to Administrator Jackson.
We’ll offer an interpretation of other points raised or answered in Ms. Jackson’s letter in a later post.
The threshold quantities are the lower of either 500 pounds or the threshold planning quantity for extremely hazardous substances, and 10,000 pounds for other hazardous substances (subject to certain exemptions that apply for hazardous wastes, tobacco, wood products, manufactured “articles,” food, drugs, cosmetics, alcohol and agricultural products, and higher thresholds for fuel storage at retail gas stations).
