Author
Options for Addressing EPA's Best Available Control Technology Top-Down Policy
STAFF CONTACT
Interstate Natural Gas Association of America
20 F Street, NW, Suite 450
Washington, DC 20001
Phone: 202-216-5923
http://www.ingaa.org
PublisherINGAA Foundation, Washington, DC
ReleasedFebruary 1, 1991
Copyright1991
Options for Addressing EPA's Best Available Control Technology Top-Down Policy

This report presents a study of the Environmental Protection Agency's (EPA's) "top-down" policy for determining "best available control technology" (BACT) under the Clean Air Act's Prevention of Significant Deterioration (PSD) program. In 1988 EPA established its "top-downt" BACT policy internally, without providing an opportunity for public comment. The purpose of this study is to document key technical, economic, and legal issues related to the top-down policy and to identify options to challenge or modify the policy or mitigate its impact on gas transmission engines.

This report presents a study of the Environmental Protection Agency's (EPA's) "top-down" policy for determining "best available control technology" (BACT) under the Clean Air Act's Prevention of Significant Deterioration (PSD) program. In 1988 EPA established its "top-downt" BACT policy internally, without providing an opportunity for public comment. The purpose of this study is to document key technical, economic, and legal issues related to the top-down policy and to identify options to challenge or modify the policy or mitigate its impact on gas transmission engines.

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