AMERICAN BAR ASSOCIATION
Section of Environment, Energy, and Resources
Air Quality Committee
New Source Review Reform: Past, Present, and Future
Tuesday, April 10, 2018
1:00 p.m. – 2:00 p.m. Eastern
Committee Program Call
Under the Clean Air Act’s New Source Review (“NSR”) program, the construction of any new major stationary source and a “major modification” at an existing major facility that results in a “significant net emissions increase” must undergo preconstruction permitting and comply with stringent emission limitations. For decades, the NSR program has drawn criticism from and calls for reform by regulated parties, who argue that the program is expensive, unwieldy, and time-consuming, even after the NSR reforms issued in 2002. With the Trump administration’s desire to streamline environmental permitting requirements, regulated parties have renewed their push for NSR reform. On December 7, 2017 and March 18, 2018, U.S. EPA Administrator Scott Pruitt issued two memoranda aimed at clarifying critical aspects of the NSR program, including the evaluation of the effects of a project on emissions, both increases and decreases, in determining NSR applicability and the EPA’s role in reviewing projected emission calculations. Please join us for a timely committee call as leading lawyers and an experienced permitting consultant analyze EPA’s recent memoranda, discuss how they could change the NSR program, provide key technical elements for project/permitting considerations and answer questions about the advantages and disadvantages of making these changes through regulatory guidance.
Gwen Keyes Fleming, Partner, Van Ness Feldman LLP
Shannon Broome, Partner, Hunton Andrews Kurth LLP
John Iwanski, Managing Director, North Region, Trinity Consultants
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Non-Member Price: $20
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This program will not offer CLE.