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A&WMA releases "updated" New Source Review Manual

On September 1, 2017, the Air and Waste Management Association (A&WMA) released the New Source Review Manual, its long-awaited “update” to EPA’s 1990 New Source Review Workshop Manual, also known as the “Puzzle Book.” The A&WMA’s New Source Review Manual follows the outline of the prior EPA document, but adds additional materials, such as the NSR Reform efforts and new chapters on NSR administration, implementation, appeals and enforcement and a history of the PSD and NNSR programs.

A&WMA has made the table of contents available for review. Short biographies of the principal authors, who include (in alphabetical order) John Evans, Eric Hiser (from NSR Law Blog), Gale Hoffnagle (NSR Law Blog guest commentator), David Jordan, Gary McCutchen and Ken Weiss, are also available.

What are the benefits of the A&WMA New Source Review Manual? As Gary McCutchen, former Chief of EPA's New Source Review section at EPA states in his introduction:

Little by little, the 1990 Manual is becoming outdated, with the greatest change occurring with the December 31, 2002, promulgation of the NSR “Reform Rule.” As much as it would like to, the EPA, with a full plate of NSR regulatory and judicial challenges in this still-extremely contentious regulatory program, has indicated—as of early January 2017—it is unable to pre­pare or even to review or endorse a new NSR Manual. …

The 2017 Manual differs significantly from the 1990 Manual in several respects. First and foremost, the 2017 version, although a final product rather than a draft doc­ument, is intended to be a “living” document that will be revised as NSR policy and rules continue to evolve…. Also, the 2017 Man­ual is less prescriptive. Since it is not an EPA product, the 2017 Manual can neither declare nor authorize any new or revised policy. Instead, it focuses on collecting, distilling, and explaining existing policy and decisions (executive and judicial) into, we hope, a reasonably coherent and useful form. The pros and cons of issues are discussed, and the authors provide what they consider to be EPA’s stance on that issue, as well as their own view of whether that stance is a reasonable one…. The 2017 Manual also recognizes the increasing role the courts have played in NSR implementation over the last 26 years … more and more implementation policies in this complex regulatory program are, for better or worse, being driven by judicial decisions rather than EPA policies and interpretations.

The A&WMA New Source Review Manual is available from A&WMA in single user ($269 member, $349 nonmember) and 5 and 10 user packages. Special rates are available for government agencies. The manual can be ordered at

Thanks to A&WMA for bringing out the new NSR manual and to the efforts of Ken Weiss and Gary McCutchen to bring it to completion.

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