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EPA Clarifies “New” Units for PAL Purposes

Aug 21, 2018

On March 13, 2018, an attorney wrote EPA requesting a clarification of how the PAL provisions worked.  The attorney advanced the argument that "an emissions unit that had commenced operation within two years of the selected baseline period constitutes a ' new source' under the NSR regulations,” contending that since the unit would be “new” relative to the baseline period, the PTE should be used.  Read more here https://www.nsrlaw.com

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