ENV-17-01 A False Sense of Security - Shifts in EPA’s Policy Regarding PSD Demand Growth Exclusion

Description:

This paper focuses on how the EPA Region IV applicability determination may have created a false sense of security to environmental practitioners as recent EPA actions have taken a more conservative approach. This technical paper presents additional EPA guidance, two recent court cases, as well as additional insight gained by the author during recent experience in performing a complex and detailed PSD applicability evaluations in the context of utilizing the DGE.