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Air Quality Permitting ISG Meeting - 3/11/16

Baron Environmental Associates regularly attends the quarterly Industrial Stakeholders Group meeting held by the NJDEP’s Air Quality Permitting Department. Each meeting gives industry an opportunity to meet with DEP policy makers, permit writers, and enforcement officers and discuss the latest developments in the sector. The latest meeting was held on Friday, March 11th. Below is a brief description of the major talking points from the meeting:

- Emission Credit Program

The opening discussion revolved around the issues being faced by the Banked Emission Credits program. In short, New Jersey is divided into two sections by the EPA (which also include some areas in surrounding states) and these two sections have separate allowances for Creditable Emission Reductions (CERs). The southern section currently has a surplus of available credits. However, the main issue affecting this program is a significant shortfall of available CERs in the northern region (brought about by the pending addition of around 10 new power generation facilities). Facilities with emissions sources due to be retired would be wise to consider entering into this program as the sale of available CERs could be lucrative.

- General Permits (GP for minor sources and GOP for major sources)

General permits GP-05b and GOP-04 for natural gas emergency generators are now available online. Until recently, these permits had been available only through written submissions. Now however, they are only available through online applications. The next GPs to be revised are expected to be GP-017a and GOP-07 (boilers from 1-5MMBtu). The hope is these GPs will be available sometime this spring in draft form for public comment. Additionally, the DEP is working towards creating a PDF of the GP as proof of purchase once the application has been accepted.

- ISG Subgroup update

The DEP is looking into incorporating additional exemptions to the permit applicability including such items as: balers, plastic extruders, conveyors and others. They are also looking into the creation of “plain language” permit guidance and the expansion of the SEGAP permit to allow for controls. As these items are still in their infancy, Baron will continue to monitor progress moving forward and provide more detailed information should one or more of these items pick up steam.

- Emission Statement and CSAPR Update

In 2014, around 80% of all emission statements were submitted electronically and the DEP continues to look at the possibility of making electronic submittal a requirement.

The EPA proposed updates in its CSAPR (Cross-State Air Pollution Rule) requirements in November of 2015. As part of this proposal, it lowered allowable total emissions of NOx throughout the country. The impact in New Jersey is set to be much lower, with a 5% reduction in actual emissions, compared to that of Pennsylvania or Ohio, who are required to cut by 60% and 50% respectively.

- Risk Screening

There have been updates to the Risk Screening worksheets. The sheets no longer sum all the risks but now calculate individual risks.

- Facebook Page

The DEP now has a Facebook page that publishes information on Air Quality, Energy and Sustainability.

For more information on ISG meetings past, present and future, you can contact Baron or visit the DEP website here.

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