MassDEP Response to EPA GHG Initiatives SIP Steering Committee January 13, 2011 Marc Wolman

MassDEP Response to EPA GHG Initiatives Reporting Rule PSD Title V BACT Guidance 2

MassDEP Response to EPA Mandatory GHG Reporting Rule EPA does not delegate to states MassDEP implemented 310 CMR 7.71 “Reporting of Greenhouse Gas Emissions” independently from federal regulation 3

MassDEP Response to GHG Tailoring for PSD No response necessary, since EPA implements PSD in Massachusetts MassDEP considering adding GHG tailoring thresholds to 310 CMR 7.54 “Large Combustion Emission Units Need explicit provisions for capping GHG emissions to avoid PSD, Title V 4

MassDEP Response to GHG Tailoring for Title V MassDEP preparing amendment to 310 CMR 7.00, Appendix C, (Title V Operating Permits) Major GHG-emitting Facility without OP must submit complete OP application, or receive final approval of OP-avoidance emissions cap by July 1, 2012 Need explicit provisions for capping GHG emissions to avoid PSD, Title V 5

MassDEP Response to EPA BACT Guidance EPA BACT Guidance applies to PSD review, by EPA in Massachusetts EPA Guidance focuses on energy efficiency MassDEP Plan Application Form revisions will include energy efficiency questionnaire MassDEP considering guidance on appropriate threshold for minor source GHG review 6