New Source Review

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By Andrew H. Perellis, Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  Consistent with guidance issued by the Environmental Protection Agency (EPA) in March 2018, the Agency has now proposed to codify changes to the New Source Review (NSR) applicability regulations to clarify the requirements that apply to sources proposing to …
Continue Reading EPA Proposes Revisions to Clarify New Source Review Permitting Process – Updating “Project Emissions Accounting”

By Jeryl L. Olson and Eric E. Boyd

On August 7th, in Summit Petroleum Corp. v. EPA, a panel of the United States Court of Appeals for the Sixth Circuit vacated a decision by the U.S. Environmental Protection Agency (EPA) that Summit Petroleum’s natural gas operations plant and wells located in a 43-square mile area near the plant were…

Continue Reading Plants Must Actually be “Adjacent” to Constitute a Single Source for Air Permitting Purposes