United States (Federal)

US-1a:Greenhouse Gas Permitting (under the Clean Air Act)

Policy Description

From 2011, under the Prevention of Significant Deterioration (PSD) program of the Clean Air Act, large industrial installations will be required to obtain permits for GHG emissions as well as for other air pollutants, and requires the implementation of Best Available Control Technologies" (BACT).

Description

Federal regulations to improve air quality have been in place since 1963, and industrial facilities have been required to obtain permits for air pollutants under the Clean Air Act (CAA) since 1990 [1] [2].

From 2011, under the Prevention of Significant Deterioration (PSD) program of the Clean Air Act, large industrial installations are required to obtain preconstruction permits for GHG emissions as well as for other air pollutants. In addition, under the Title V operating permits program, large facilities must limit their greenhouse gas (GHG) emissions to obtain an operating permit. Both programs require implementation of "Best Available Control Technologies" (BACT) for GHG control. BACT does not establish specific standards for GHG emissions for any particular source. It is a case-by-case decision that considers energy, environmental, and economic impact.

 

Permitting requirements for air pollutants under the CAA

In December 2008, the US Environmental Protection Agency (EPA) issued a memo introducing the PSD program that requires that all new “major sources,” and all major sources undertaking modifications that result in a “significant” increase in emissions, obtain preconstruction permits and install “best available control technology” (BACT) for all pollutants subject to regulation. (*7). In addition, sources emitting over 100 tons per year (tpy) of a regulated pollutant are generally required to obtain an operating permit under title V of the Clean Air Act. While this threshold is appropriate for criteria pollutants, they are not feasible for GHGs because GHGs are emitted in much high volumes. Therefore, the EPA established a tailoring rule for GHGs (see section below).

Adding GHG emissions to the CAA permitting requirements

In May 2010, EPA finalized a rule adding greenhouse gas (GHG) emissions under the PSD and Title V programs. This rule specifies that large industrial facilities -such as power plants and oil refineries that are in total responsible for 70 percent of the GHGs - are required to obtain permits under the PSD and Title V programs [3].

The “Tailoring Rule,” issued in May 2010, established emission thresholds and a phased timetable for permitting (*7) (*10). The Tailoring Rule also introduced the “one-step-at-a-time” approach – under which administering agencies may follow a step-wise approach to include the stationary sources under the permitting scheme. 

 The requirements are being phased-in through a series of four steps as follows:

  • In step 1, which ran from January to June 2011, no new permitting actions due solely to GHG emissions were required. Facilities undertaking permitting actions for other pollutants needed to address GHGs if they increased GHG emission by 75,000 tpy CO2e or more and if they were undergoing a renewal or revision of their permits for other air pollutants [4].
  • In step 2, which runs from July 2011 to June 2013, all facilities with GHG emissions of at least 100,000 tpy are subject to the Title V operating permit requirements. In addition, a PSD permit is required for new facilities with GHG emissions of at least 100,000 tpy, and a PSD permit is required for existing facilities with at least 100,000 tpy CO2e making changes that would increase GHG emissions by at least 75,000 tpy [5]. If EPA finds that a violation has occurred, the agency can issue an order requiring the violator to comply, use EPA administrative authority to force payment of a penalty, or sue the violator in court [6].
  • The third step, issued in June 2012, does not change the permit applicability thresholds. It does, however, revise the plant wide applicability limitations (PALs) regulations. A PAL is an emissions limit applied sourcewide rather than to specific emission points. With a PAL, a source can make changes to the facility without triggering PSD permitting requirements as long as emissions do not increase above the limit established by the PAL[7] [8] (*8).
  • EPA is required to issue Step 4 by April 2016. In this step, applicability thresholds will be revisited and potentially revised based on the results of a five year study that will examine the administrative costs associated with regulating sources at lower GHG emissions thresholds [9].

Best Available Control Technology (BACT) standards

Installations covered by the permitting requirements must install "Best Available Control Technology" (BACT) for every pollutant subject to regulation under the CAA. BACT is an emissions limitation which is based on the maximum degree of control that can be achieved by a particular facility (but BACT does not specify maximum CO2 emissions allowed by the specific technology operated at the facility). It is a case-by-case decision that considers energy, environmental, and economic impact. BACT can be add-on control equipment or modification of the production processes or methods. This includes fuel cleaning or treatment and innovative fuel combustion techniques. BACT may be a design, equipment, work practice, or operational standard if imposition of an emissions standard is infeasible [10]. The RBLC database (see: cfpub.epa.gov/RBLC/) contains case-specific information on the "Best Available" air pollution technologies that have been required to reduce the emission of air pollutants from stationary sources.

The BACT requirements for GHGs were defined by EPA on November 10, 2010 and provide guidance on technologies to be employed. The guidance provided by EPA involves a five step process to determine BACT for GHGs [11]:

Step 1: Identify all available control technologies.

Step 2: Eliminate technically infeasible options.

Step 3: Rank remaining control technologies.

Step 4: Evaluate most effective controls and document results.

Step 5: Select the BACT.

 

The five step process guides permit writers and permit applicants in determining BACT, which takes into account technical feasibility, cost, and other energy, environmental, and economic impacts. EPA provides additional guidance for conducting BACT analyses in eight specific industrial sectors (See: http://www.epa.gov/nsr/ghgpermitting.html).

Policy Information Expand this section for information on the key features of the policy, such as its date of introduction, categorization, main objective(s) and linkages with other policies.

Policy Categorisation

Policy Instrument Type: Administrative

Position in the Pyramid

About Us

Participation: Mandatory

Period

Start Date: 2010

Policy Linkages

Supported By Business Energy Investment Tax Credit (ITC) Supporting Measure
Complements New Source Performance Standards (under the Clean Air Act) Effort Defining

Agencies Responsible

Environmental Protection Agency

Primary Objective: GHG Emissions

Objective

The CAA in general aims to protect human health and the environment by reducing emissions into the air. The permitting program specifically aims to: 1. Prevent violations of the Clean Air Act National Ambient Air Quality Standards and protect the environment; 2. Protect the air quality and visibility in national parks, national wilderness areas and other areas of special natural, recreational, scenic, or historic value; 3. Allow economic growth while limiting impacts on good air quality; 4. Require the Best Available Control Technology (BACT) for new or modified major sources of air pollution to minimize air pollution. GHG emissions are included in the permitting program since 2011 in response to the EPA’s Endangerment Finding, signed on December 7, 2009 [12].

Target Group

While the CAA targets both stationary and mobile sources of air pollution, the GHG permitting requirements are specifically targeted at large stationary sources of air pollution due to the Tailoring Rule. Under the Rule, emissions thresholds mean that only the largest emitters, such as cement production facilities, chemical plants, refineries, and power plants are covered according to a phased implementation [13] (see below "Requirements on the Target Group" in Policy Implementation).

Driver of energy consumption or emissions affected by policy: Total GHG emissions

Implementation Information Expand this section for information on targets, monitoring, verification and enforcement regimes, and implementation requirements and tools.

Coverage

Large stationary sources that release air pollutants. Coverage will increase over time (2011-2016) according to the Tailoring Rule (see "Requirements on the Target Group"). In terms of the number of facilities subject to this rule, there are more facilities in the industry sectors compared to power plants. In terms of amount of GHG emissions, however, there are much more from power plants vs. industry. See: http://ghgdata.epa.gov/ghgp/main.do

Quantitative Target? no

Target: Target emissions levels are not prescribed. Instead, the rule specifies that facilities apply BACT. EPA provides basic technical information which may be useful in a BACT analysis, but they do not define BACT.

Time Period: 2011-ongoing

Progress Monitored? yes

Verification Required? yes

Enforced? yes

Sanctions: When EPA finds that a violation has occurred, the agency (at state level) can issue an order requiring the violator to comply, issue an administrative penalty order (using EPA's administrative authority to force payment of a penalty), or bring a civil judicial action (sue the violator in court) [14].

Requirements on the Target Group

 

Large industry and commercial companies that release pollutants into the air must comply with the operating permit program [15] (*3) according to the U.S. Code of Federal Regulations [16];

The Tailoring Rule [17] was defined to ensure that current businesses planning was not affected by the Clean Air Act requirements. The Tailoring Rule established a phased implementation plan and increased the thresholds for emitters to be covered by these requirements (see “Adding GHG emissions to the permitting requirements” under Policy Description).

BACT implementation

To obtain a Prevention of Significant Deterioration (PSD) or Title V operating permit, the application must contain emissions limitations based on application of BACT for each regulated pollutant. A determination of BACT for GHGs should be conducted in the same manner as it is done for any other regulated pollutant. EPA recommends that permitting authorities continue to use the EPA's five-step “topdown” process:

Step 1: Identify all available control technologies. 
Step 2: Eliminate technically infeasible options. 
Step 3: Rank remaining control technologies. 
Step 4: Evaluate most effective controls and document results. 
Step 5: Select the BACT.

BACT is an emissions limitation which is based on the maximum degree of control that can be achieved by a particular facility. It is a case-by-case decision that considers energy, environmental, and economic impact [18]. (See “BACT standards,” under Policy Description.)

General permitting requirements:

• Reporting requirements: Annual GHG emissions of the facility must be reported (*2);
• Verification of these emissions should be done by professional engineers, which could be in-house experts. Sanction on incorrect verification is loss of license for verifier.
• Monitoring methods: Facilities must use best available methods and begin following the applicable monitoring and Quality Assurance/Quality Control requirements provided by the rule;
• Recordkeeping Requirements.

Support by Government

 

EPA assists state, tribal, and local agencies by providing research, expert studies, engineering designs, and funding to support clean air progress [19]. Since 1970, Congress and the EPA have provided several billion dollars to states, local agencies, and tribal nations to accomplish this.

Implementation Toolbox

The main tools supporting implementation of GHG BACT permitting requirements under the Clean Air Act are:

  • White Papers on GHG Control Measures – These technical “white papers” focus on the industrial sectors listed below that emit the highest amounts of GHGs. They provide basic information on GHG control options to assist states and local air pollution control agencies, tribal authorities and regulated entities implementing measures to reduce GHGs, particularly in the assessment of Best Available Control Technology (BACT). These papers provide basic technical information that may be useful in a BACT analysis but they do not define BACT for each sector. Sectors and technologies covered include:
    •  Electric generating units
    •  Large boilers
    •  Pulp and paper
    •  Cement
    •  Iron and steel
    •  Refineries
    •  Nitric acid
    •  Landfills

The White Papers can be found at http://www.epa.gov/nsr/ghgpermitting.html [20]

  • Control Technology Clearinghouse (known as the RACT/BACT/LAER Clearinghouse, or the RBLC) – This website provides access to information and decisions about pollution control measures required by air pollution emission permits that will be issued for GHGs by state and local permitting agencies. The information is accessible to all permitting agencies working on similar projects. The expanded RBLC includes GHG control and test data and a GHG message board for permitting authorities.   See http://www.epa.gov/ttn/catc/rblc/htm/welcome.html 
  • PSD and Title V Permitting Guidance for Greenhouse Gases – This EPA document provides information that permit writers and applicants need to address GHG emissions in permits. The document provides background information, PSD applicability criteria, EPA’s recommended BACT analysis, other PSD requirements, and Title V considerations. See http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf
  • Modular Training on Greenhouse Gas Permitting – Video training materials on GHG permitting. See http://www.epa.gov/apti/broadcast2010.html#GHGTraining1210
  • GHG Permitting Action Team – This team, comprised of experienced senior staff and permitting managers from EPA, is available to assist permitting authorities respond to GHG permitting questions. 

 

Complexity of Implementation

Government

BACT have to be defined, which means operationalising and quantifying the concept of 'Best Available Control Technology'. Instead of defining a long list of technologies per sector (as was experienced in the similar establishment of BAT and BREF documents under the European IPPC regulation), the EPA provides guidance that permitting authorities may use when determining BACT (See BACT implementation and www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf) (*11).

Target Group

Monitoring and reporting is time consuming and requires specialist knowledge. Costs are medium level.

Impacts, Costs & Benefits Expand this section to find information on policy effectiveness and efficiency.

Impact Quantitative Estimate Qualitative Estimate
Estimated effect on energy consumption or emissions EPA estimated that in total (over the three phases) 14,000 large industrial sources would need to obtain greenhouse gas permits, and about 3,000 of those sources would be newly subject to Clean Air Act operating permit requirements [21] Total effect on GHG emissions is potentially large if strict BACT would be specified or targets would be connected to the permit setting. Short-term effects however will be low since a) a gradual implementation phase is followed; b) BACTs are not specified; and c) absolute emission limits are not set.
Estimated costs/benefits for industry The direct costs of implementing the Clean Air Act from 1970 to 1990, including annual compliance expenditures in the private sector and program implementation costs in the public sector, totalled $523 billion in 1990 dollars (*10). These direct costs include O&M costs, capital costs and R&D expenditures [22]. The estimated direct costs of the CAA from 1990-2010 are estimated at a net present value of $180 billion estimated in inflation-adjusted 1990 dollars, discounted to 1990 at five percent [23]. Note that the CAA is much broader than the GHG portion of the Act. N/A
Estimated cost for government Not available. N/A
Other Benefits
General Benefits Significant reductions in air pollution emissions achieved by the Act (*4). Reports from EPA and the Office of Management and Budget mention that in the period 1970-1990 emissions of the most common air pollutants have declined by 41 percent, while Gross Domestic Product (GDP) has increased by more than 64 percent. [24] This was however before GHG emissions were included.
Specific Benefits The direct benefits of the Clean Air Act from 1970 to 1990 (i.e. not including GHG emission reductions!) include reduced incidence of a number of adverse human health effects, improvements in visibility, and avoided damage to agricultural crops. Based on the assumptions employed, the estimated economic value of these benefits ranges from $5.6 to $49.4 trillion, in 1990 dollars, with a mean, or central tendency estimate, of $22.2 trillion [25]; The estimated direct benefits of the CAA from 1990-2010 are estimated at a net present value of $690 billion estimated in inflation-adjusted 1990 dollars, discounted to 1990 at five percent [26], [27]; Other benefits are: • Economic benefits (creation of millions of jobs; estimate for 1977-1991 was 1.3 million total jobs) • Spawns innovative solutions and lowers costs.

References & Footnotes

References

[1] United States Environmental Protection Agency, Understand: http://www.epa.gov/air/peg/understand.html

[2] United States Environmental Protection Agency, Operating Permits: http://www.epa.gov/air/oaqps/permits/

[3] Danish K., Carbonell T., and Ceronsky M, (2010). EPA Issues “Tailoring Rule” Outlining Clean Air Act Permitting Thresholds for Facilities that Emit Greenhouse Gases, Issue ALert, May 2010: http://www.vnf.com/assets/attachments/612.pdf

[4] Mangino, Joseph. "Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule." United States Environmental Protection Agency, June 2010. .

[5] United States Environmental Protection Agency. PSD and Title V Permitting Guidance for Greenhouse Gases. March 2011. .

[6] United States Environmental Protection Agency, Permits and Enforcement http://www.epa.gov/air/peg/permits.html

[7] United States Environmental Protection Agency, Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule Step 3 and GHG Plantwide Applicability Limits: http://www.gpo.gov/fdsys/pkg/FR-2012-07-12/pdf/2012-16704.pdf

[8] United States Environmental Protection Agency (2012). Factsheet: Final Rule - Prevention of Significant Deterioration and Title V Operating Permit Greenhouse Gas (GHG) Tailoring Rule Step 3 and GHG Plantwide Applicability Limits. Retrieved 10 October 2012 from http://www.epa.gov/nsr/documents/20120702fs.pdf

[9] United States Environmental Protection Agency, Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule Step 3 and GHG Plantwide Applicability Limits: http://www.gpo.gov/fdsys/pkg/FR-2012-07-12/pdf/2012-16704.pdf

[10] United States Environmental Protection Agency, Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule Step 3 and GHG Plantwide Applicability Limits: http://www.gpo.gov/fdsys/pkg/FR-2012-07-12/pdf/2012-16704.pdf

[11] United States Environmental Protection Agency. "Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act." .

[12] United States Environmental Protection Agency. "Endangerment and Cause or Contribute Findings for Greenhouse Gases under Section 202(a) of the Clean Air Act." .

[13] http://www.epa.gov/NSR/documents/20100413final.pdf

[14] United States Environmental Protection Agency, Permits and Enforcement http://www.epa.gov/air/peg/permits.html

[15] United States Environmental Protection Agency, Permits and Enforcement http://www.epa.gov/air/peg/permits.html

[16] Legal Information Institute of the Cornell University Law School, U.S. Code: http://www.law.cornell.edu/uscode/html/uscode42/usc_sec_42_00007661----000-.html

[17] http://www.epa.gov/NSR/documents/20100413final.pdf

[18] United States Environmental Protection Agency. “Prevention of Significant Deterioration (PSD) Basic Information.” .

[19] United States Environmental Protection Agency, Understand: http://www.epa.gov/air/peg/understand.html

[20] United States Environmental Protection Agency (2011). PSD and Title V Permitting Guidance for Greenhouse Gases. Retrieved 1 December 2011 from http://www.epa.gov/nsr/ghgdocs/ghgpermittingguidance.pdf

[21] Jones E. (2010). "EPA Proposes Rules on Clean Air Act Permitting for Greenhouse Gas Emissions", 08/12/2010: http://yosemite.epa.gov/opa/admpress.nsf/e77fdd4f5afd88a3852576b3005a604f/708bd315d348b5568525777d0060c5da!OpenDocument

[22] United States Environmental Protection Agency (2007). EPA Report to Congress, "The Benefits and Costs of the Clean Air Act, 1970 to 1990" http://yosemite.epa.gov/ee/epa/eerm.nsf/vwRepNumLookup/EE-0295?OpenDocument

[23] United States Environmental Protection Agency (1999). “The Benefits and Costs of the Clean Air Act, 1990 to 2010": http://yosemite1.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0295A-01.pdf/$file/EE-0295A-01.pdf

[24] Small Business Majority and The Main Street Alliance, The Clean Air Act’s Economic Benefits Past, Present and Future, Oct 2010 http://mainstreetalliance.org/wordpress/wp-content/uploads/2010/10/Benefits-of-CAA-literature-review-final-10-04-2010.pdf

[25] United States Environmental Protection Agency (1999). “The Benefits and Costs of the Clean Air Act, 1990 to 2010": http://yosemite1.epa.gov/ee/epa/eerm.nsf/vwAN/EE-0295A-01.pdf/$file/EE-0295A-01.pdf

[26] http://www.epa.gov/NSR/documents/20100413final.pdf

[27] Danish K., Carbonell T., and Ceronsky M, (2010). EPA Issues “Tailoring Rule” Outlining Clean Air Act Permitting Thresholds for Facilities that Emit Greenhouse Gases, Issue ALert, May 2010: http://www.vnf.com/assets/attachments/612.pdf

[28] Jones E. (2010). "EPA Proposes Rules on Clean Air Act Permitting for Greenhouse Gas Emissions", 08/12/2010: http://yosemite.epa.gov/opa/admpress.nsf/e77fdd4f5afd88a3852576b3005a604f/708bd315d348b5568525777d0060c5da!OpenDocument

[29] Hult, M., (2010). AWMA-UMS Regulation of Greenhouse Gases (GHG) under the Clean Air ActMay 6, 2010, Tailoring Rule, Johnson Memorandum, PSD Timing: http://www.awma-ums.org/presents/2010_05_06/GHGTailoring.pdf

[30] United States Environmental Protection Agency (2010). Factsheet: Clean Air Act Permitting for Greenhouse Gases: Guidance and Technical Information. Retrieved 1 December 2011 from http://www.epa.gov/nsr/ghgdocs/ghgpermittingtoolsfs.pdf

[31] Hult, M., (2010). AWMA-UMS Regulation of Greenhouse Gases (GHG) under the Clean Air ActMay 6, 2010, Tailoring Rule, Johnson Memorandum, PSD Timing: http://www.awma-ums.org/presents/2010_05_06/GHGTailoring.pdf

[32] United States Environmental Protection Agency, Environmental Laws (1997) http://www.epa.state.oh.us/portals/41/sb/publications/envlaws.pdf

[33] United States Environmental Protection Agency, Clean Air Act as of 2008: http://www.gpo.gov/fdsys/pkg/USCODE-2008-title42/pdf/USCODE-2008-title42-chap85.pdf

[34] IEA (2007). Energy Policies of IEA Countries: United States 2007: http://www.oecd-ilibrary.org/energy/energy-policies-of-iea-countries-united-states-2007_9789264030749-en

[35] United States Environmental Protection Agency, Operating Permits: http://www.epa.gov/air/oaqps/permits/

[36] United States Environmental Protection Agency. PSD and Title V Permitting Guidance for Greenhouse Gases. March 2011. .

Footnotes

(*1) Industries have defined their targets into different ways: - improvements in the level of energy input per unit of output (value added) or CO2 emission per unit of output (value added) ; - reduction in the total amount of energy used or CO2 emitted; - energy conservation measures that seek to lower energy consumption during the stage in which services are provided or products are used.

(*2) The following GHG must be reported: carbon dioxide, methane, nitrous oxide, sulfur hexafluoride, hydrofluorocarbons, perfluorocarbons, other fluorinated gases (e.g., nitrogen trifluoride, hydrofluorinated ethers)

(*3) Operating permits include information on which pollutants are being released, how much may be released, and what kinds of steps the source's owner or operator is required to take to reduce the pollution. Permits must include plans to measure and report the air pollution emitted. States and tribes issue operating permits. If those governments do not do a satisfactory job of carrying out the Clean Air Act permitting requirements, EPA can take over issuing permits.

(*4) Sulfur dioxide (SO2) emissions declined 40 percent as a result of the Clean Air Act; nitrogen oxide (NOx) emissions were reduced by 30 percent; volatile organic compound (VOC) emissions were reduced by 45 percent; carbon monoxide (CO) emissions were reduced by 50 percent; particulate matter (PM) emissions were reduced by 75 percent; and lead emissions were reduced by 99 percent.

(*5) Under the CAA the U.S. Environmental Protection Agency (EPA) sets National Ambient Air Quality Standards (NAAQS) to protect public health and the environment [32]. States are required to meet NAAQS through state implementation plans (SIPS) (*5) that help control the emissions of air pollutants. Since 1990 permit requirements are also part of the CAA for larger industrial and commercial sources that release pollutants into the air. The permit includes information on which pollutants are being released, how much may be released, and actions required from the operator to reduce emissions [33], [34] (*6). Permits must include monitoring and reporting plans. The permits are often referred to as part 70 permits as the regulations establishing minimum standards for State permit programs are included in the Code of Federal Regulations at 40 CFR part 70 [35]. The State Implementation Plan (SIP) is a plan for each State which identifies how that State will attain and/or maintain the primary and secondary National Ambient Air Quality Standards (NAAQS) set forth in section 109 of the Clean Air Act ("the Act") and 40 Code of Federal Regulations 50.4 through 50.12 and which includes federally-enforceable requirements.

(*6) The 1990 amendment identifies 188 Air Toxics (hazardous air pollutants), directs EPA to identify sources of the 188 pollutants, and establishes a ten-year time period for EPA to issue technology-based emissions standards for each source category.

(*7) Under the Clean Air Act, a “major source” is an entity that emits or has the potential to emit 100 or 250 tons per year (tpy) of a pollutant, depending upon the type of source, and the default “significance” threshold for modifications is any increase in pollutant emissions resulting from the modification.

(*8) In the first rule, EPA required permitting programs in 13 states to make changes to their implementation plans to ensure that GHG emissions will be covered. All other states that implement an EPA-approved air permitting program must review their existing permitting authority and inform EPA if their programs do not address GHG emissions. Because some states were not able to develop and submit revisions to their plans before the Tailoring Rule became effective in 2011, in the second rule, EPA initiated a federal implementation plan, which allows EPA to issue permits for large GHG emitters located in these states. This is a temporary measure that is in place until the state can revise its own plan and resume responsibility for GHG permitting.

(*9) PSD permitting requirements apply only to sources that: (1) make modifications resulting in increases of GHG emissions by 75,000 tons carbon dioxide-equivalent (CO2e) per year or more; and (2) are already required to obtain PSD permits on account of emissions of pollutants other than GHGs. Sources that are already required to obtain, renew, or revise their title V permits as a result of non-GHG emissions need to include GHG emissions in their permit applications.

(*10) Direct costs are imposed by regulations promulgated under the amendments, will also be seen in patterns of industrial production, research and development, capital investment, productivity, employment, and consumption. Titles I to V of CAA: - Title I- Provisions for Attainment and Maintenance of NAAQS, - Title II- Provisions Relating to Mobile Sources, - Title III- Hazardous Air Pollutants - Title IV- Acid Deposition Control, - Title V- Permits

(*11) The “PSD and Title V Permitting Guidance for Greenhouse Gases” guidance document describes the requirements of the PSD and title V permit regulations; reiterates and emphasizes relevant past EPA guidance on the PSD and title V review processes for other regulated air pollutants; and provides additional recommendations and suggested methods for meeting the permitting requirements for GHGs, which are illustrated in many cases by examples [36].