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State NSR Program Roundup #2: July 1 through September 30, 2017

The state NSR program update reviews EPA actions in approving, conditionally approving, or disapproving state implementation plan programs under any of the three NSR programs: minor NSR, PSD and/or NNSR. This edition reviews plan actions from July 1, 2017 through September 30, 2017. We start with NSR program approvals, then list nonattainment area plan approvals (which is when the area specific NSR program becomes effective) and end with infrastructure SIP approvals. In the Commentary at the end, we discuss any trends observable in EPA’s state program actions.



On August 15, 2017, EPA proposed, 82 Fed. Reg. 38660, and on October 10, 2017, 82 Fed. Reg. 46921, EPA took final action to approve:

  • The revisions to Alabama’s PSD program, updating ADEM r. 335-3-14-.04’s PAL provisions to include new greenhouse gas language from EPA’s greenhouse gas Step 3 rule; and

  • The revisions to Alabama’s PSD program to eliminate a major source based solely on emissions of greenhouse gases.

EPA took no action on any of the other elements of ADEM’s SIP submittal.

On August 24, 2017, EPA gave direct final approval to changes to the Alabama PSD SIP at 335-3-14-.04 that approved the addition of a definition of “replacement unit” and amended the definition of “emissions unit” to make it clear that a “replacement unit” is an existing unit for PSD purposes. 82 Fed. Reg. 40072. On October 12, 2017, EPA gave notice that it had received two adverse comments and was withdrawing the rule and would proceed under the notice of proposed rulemaking. 82 Fed. Reg. 47397.


On September 18, 2017, EPA proposed to approve revisions to Arkansas’ minor NSR program sections 19.401, 19.407(C)(2)(a) and (b), and 19.417. 82 Fed. Reg. 43506. The proposed changes would generally increase the minor NSR and de minimis NSR levels in the Arkansas minor NSR program to the EPA significant emission rate levels for all criteria pollutants except CO (75 tpy) and lead (unchanged) and add a de minimis level for PM at 25 tpy. The significant levels for other PSD pollutants are not addressed. 82 Fed. Reg. 43506. EPA recognized that this is a “reduction” in the stringency of the SIP. Facilities newly exempt under this provision still must give notice to ADEQ and undergo technical review to ensure they will not cause or contribute to a NAAQS violation, but do not require public notice and comment and may commence construction immediately after giving notice. EPA undertook at 110(l) analysis that focused on the total de minimis impact on the source inventory was under 1%; that all monitors except one area showed decreasing ambient levels and that the one exception was likely due to increased motor vehicle traffic in a rapidly growing area; and a combined CMAQ/AERMOD modeling analysis of hypothetical sources in various locations state-wide that showed some increase in ambient levels and design values (DVs), but all DVs stay below NAAQS.


Bay Area Air Quality Management District. On September 14, 2017, 82 Fed. Reg. 43202, EPA proposed to conditionally approve and on December 17, 82 Fed. Reg. 57133, finally conditionally approved changes to the BAAQMD Regulation 2, Rule 2-4 on emission reduction credits (ERCs). EPA conditionally approved because (1) the definition of ERC in the rule did not require BAAQMD to address EPA’s offset integrity criteria prior to granting an ERC certificate, (2) Rule 2-4 continues to rely on partially disapproved Rule 2-2’s “potential to potential” approach, meaning that some emissions that are not “actual” emissions reductions may receive credit, and (3) Rule 2-4 does not adequately provide for the permanency of an ERC resulting from a shutdown. 82 Fed. Reg. at 43203-04.

Imperial County Air Pollution Control District. On September 5, 2017, EPA gave conditional approval to Imperial County Air Pollution Control District (ICAPCD) rule 207 (New and Modified Stationary Source Review). 82 Fed. Reg. 41895. EPA determined that Rule 207 does not fully meet NNSR criteria because it does not address ammonia as a PM2.5 precursor. However, EPA found that ICAPCD has committed to address this deficiency and hence gave conditional approval.

Mendocino County Air Quality Management District. On July 3, 2017, EPA issued a limited approval and limited disapproval of changes to the Mendocino County Air Quality Management District’s new source review permitting rules. 83 Fed. Reg. 30770. The rules that were approved included: Rule 1-130 Definitions; Rule 1-200 Permit Requirements; Rule 1-230 Action on Applications. The rule that received limited approval and disapproval was Rule 1-220 New Source Review Standards (including PSD). EPA found that Rule 1-220 was deficient because it did not provide for use of Part 51, Appendix W approved models and hence did not meet 40 CFR 51.160(f) or 51.166(l). It also found that Rule 1-220 did not include the source obligation requirements of 40 CFR 51.166(r)(1) and (2). Accordingly, EPA issued a limited approval and disapproval and noted the start of the FIP clock.

South Coast Air Quality Management District. On September 14, 2017, EPA approved an update to the South Coast Air Quality Management District (SCAQMD) RECLAIM program. 82 Fed. Reg. 43176. While most of the update is not related to the NSR program, EarthJustice had objected to the approval of Rule 2005, New Source Review for Regional Clean Air Incentives Program on the basis that it did not meet CAA requirements. EarthJustice claimed that Rule 2005 (among other rules) failed to adequately prevent emission reduction credits from shut downs from entering the market. EPA responded by noting that the new rules reduced the amount of shut down ERCs entering the market and that there is no requirement that the limitations be applied retroactively before the new rule was adopted. EarthJustice also argued that the revision failed to comply with California law, but EPA stated that compliance with state law is not required, so long as local authorities can administer the program and the California Air Resources Board had provided such a certification. Accordingly, EPA finalized the SIP revision.


On August 17, 2017, EPA proposed to approve and on October 12, 2017, finally approved revisions to the Colorado State Implementation Plan proposed by the Colorado Department of Health in February 2015. 82 Fed. Reg. 39396 (proposal); 82 Fed. Reg. 47380 (final). The approved changes are as follows:

  • Changes to revise the significant impact levels (SILs) in Part D, Section V.A.2.c and significant monitoring concentrations (SMCs) in Part D, Section VI.B.3.a.(iii) for PM2.5. EPA noted that in 2013, the D.C. Circuit had vacated and remanded the PM2.5 SIL and SMC and that EPA had removed the SIL and promulgated an SMC of zero. EPA found that this change was consistent with law and strengthened the SIP.

  • Changes to the Air Pollutant Emissions Notice (APEN) in Part A, Section II.A and following, to change reporting from facility-wide to unit-specific for purposes of filing revisions. The APEN is part of the minor NSR program and the goal was to reduce the number of filings and also to allow new owners to file an abbreviated form. EPA found that these changes were consistent with the CAA.

  • Changes to the public notice provisions in Regulation 3, part B, Section III.C, to allow use of prominent display in the Department’s website in lieu of newspaper publication, consistent with EPA policy statements was found consistent with the Act.


On July 3, 2017, EPA issued a direct final rule that approved revisions to numerous definitions in Florida’s NSR programs and eliminated a lead “significant impact level”. 82 Fed. Reg. 30767.

On August 10, 2017, EPA proposed to approve and on October 6, 2017 gave final approval to a number of changes to the Florida SIP submitted by the Florida Department of Environmental Protection on June 23, 1999, July 1, 2011, December 12, 2011, and February 27, 2013, and February 1, 2017. 82 Fed. Reg. 37379 (proposed rule); 82 Fed. Reg. 46682 (final rule). EPA proposed the following actions:

  • Rule 62–210.200, F.A.C., ‘‘Definitions’’. EPA proposes to approve the revisions to the definitions as they clarify application of the regulation and do not affect any substantive change.

  • Rule 62–210.310, F.A.C., ‘‘Air General Permits’’. This rule provides for 17 general permits or permits-by-rule, 6 of which contain provisions which allow sources to avoid becoming major and 11 of which are otherwise adequate to ensure minor status. EPA proposes to approve all 17 general permits.

  • Rule 62–210.350, F.A.C., ‘‘Public Notice and Comment.” The revisions allow construction and operation permit notices to be combined, so long as all requirements of all programs are met. EPA agreed that this approach complies with the CAA.

  • Rule 62–296.100, F.A.C., ‘‘Purpose and Scope’’. EPA approved a minor reorganization of existing language and clarification that rules under multiple sections may apply.

  • EPA approved the repeal of Rule 62-210.920, “Air General Permit Forms.” EPA approved because these forms have been replaced with an on-line system.


On August 15, 2017, EPA gave direct final approval of certain changes to the Georgia NSR program initially submitted by the Georgia Environmental Protection Division (EPD) on December 15, 2011, July 25, 2014, and November 12, 2014 on clean units, greenhouse gas PALs, and updating the definition of regulated NSR pollutant. 82 Fed. Reg. 38605. EPA subsequently received an adverse comment on proposed changes to Rule 391-3-1-.02(7). As a result, EPA withdrew its direct final approval of that approval. EPA did not propose to reopen the comment period. On October 16, 2017, EPA resolved that adverse comment and gave final approval to changes to the GA EPD NSR program as follows. The approved changes include:

  • Revisions to Rule 391-3-1-.02(7) PSD, including changes needed to address PM2.5 condensable precursors and to allow greenhouse gas PALs.

  • Revisions to Rule 391-3-1-.03(8) NNSR, including changes at paragraphs (g) and (d) to allow greenhouse gas PALs.

  • EPA also approved deletion of references to clean units.

EPA did not act on proposed changes to definitions in Rule 391-3-1-.01(lll) through (nnnn) or proposed changes to the ambient air quality standards.

On August 31, 2017, EPA approved updated incorporations by reference to reflect the current codification. 82 Fed. Reg. 41337.

On September 25, 2017, EPA approved additional changes to Rule 391-3-1-.03(13), which (1) expanded the eligibility of sources in Barrow county to participate in the emission reduction credit (ERC) program under NNSR, (2) removed an exemption from the ERC discounting rule that allowed ERCs from shutdowns not to undergo discount, (3) allowed owners to re-evaluate discounted credits for accuracy, and (4) revised ERC program fees. 82 Fed. Reg. 44519.


On September 15, 2017, EPA gave direct final approval to revisions to the Iowa state implementation plan, including the chapters on definitions, minor sources, nonattainment areas, and PSD. 82Fed. Reg. 43303. In chapter 22, subrule 22.1(2) include updated exemptions from construction permitting to clarify that PAL sources may use the exemptions, make minor typographical changes, change the number of copies of the permit application. Chapter 33 is updated to include current federal rule language and bring greenhouse gas applicability into conformance with federal requirements.


On August 28, 2017, EPA gave final approval to revisions of Maryland’s administrative procedures for granting and denying permits. 82 Fed. Reg. 40710. The revisions eliminated administrative review and substituted direct judicial review of contested permits, expanded standing to contest a permit, and added additional public notice requirements for some sources. Affected provisions are COMAR, and

On September 29, 2017, EPA issued a direct final rule approving changes to the Maryland NNSR program. 82 Fed. Reg. 45475. Marylands’ NNSR program is codified at COMAR 26.11.17. Maryland had submitted a certification that COMAR 26.11.17 was at least as stringent as the federal rules. EPA agreed, finding that concerns about the lack of “extreme” area conditions were not fatal because Maryland does not have an extreme area, that the antibacksliding provisions were met because the current SIP was more stringent. Accordingly, EPA gave direct final approval that COMAR 26.11.17 continues to meet federal approvability criteria.


On August 15, 2017, EPA proposed to approve revisions to the Michigan State Implementation Plan related to permits to install (PTI). 82 Fed. Reg. 38651. This proposed action addressed state submittals dated November 12, 1993, May 16, 1993, April 3, 1998, September 2, 2003, March 24, 2009 and February 28, 2017. EPA had issued a proposed disapproval of the 1993, 1996 and 1998 submittals on November 9, 1999, but never finalized action. In this action, EPA found that the “revisions to the Part 2 submitted by MDEQ are largely provisions that strengthen the already submitted approved minor NSR program adding greater detail with respect to applicability, required application material, and processing,” but noted that there were also some “waiver” and “exemption” provisions. EPA stated that it would not act on proposed changes to the Michigan public review process at R 336.1205 in this action. EPA proposed the following actions:

  • R 336.1202(1). This provision would allow certain work prior to permitting. EPA notes that this is not forbidden by the PSD program for non-major sources, but must still meet CAA section 110 requirements. In this case, MDEQ proposes to require an application to undertake such construction, limits what may be approved, and prohibits construction or reconstruction under Parts 61 or 63. EPA found that this provision is consistent with the act and proposal approval.

  • Source exemptions at R 336.1278, 1278a, 1280-1290. In reviewing this, EPA stated its concern is to ensure no major source escapes regulation, that there is adequate records for the state to enforce, and that the exemptions would not interfere with the NAAQS, CAA requirements or reasonable further progress. R 336.1278 prohibits use of the exemption by sources subject to major source requirements and imposes recordkeeping requirements and defines activity as all “concurrent and related installation, construction, reconstruction, relocation, or modification of any process or process equipment,” which EPA found would result in proper aggregation before applying an exemption. R 336.1278a imposes a demonstration requirement. MDEQ then demonstrated that emissions were low (likely less than 3 tons/year) or provided a demonstration where emissions were 10 tons/year or more that no impact on NAAQS was anticipated. Accordingly, EPA proposed to approve these provisions.

EPA extended this comment period on November 2, 2017 and then reopened it again period on January 9, 2018 due to a missing attachment.


On July 10, 2017 EPA proposed approval, and on September 26, 2017, EPA gave final approval to Minnesota R. 7007.3000, which incorporates the federal PSD program at 40 CFR 52.21 by reference as the state’s PSD program, excepting only certain functions reserved to EPA at section 52.21(g), (s)-(u). 82 Fed. Reg. 44734. Commenters asked whether this incorporation means that federal rule changes take effect on the federal date and both EPA and MPCA state that they will.


On August 8, 2017, EPA published a direct final rule approving changes to the Mississippi PSD program. 82 Fed. Reg. 32017. The approved changes included:

  • Approved the renaming of the PSD rules from “APC-S-5” to “Regulation 11-MAC-2-5.”

  • Approved updating the incorporation by reference date from November 4, 2011 to February 17, 2016. This has the effect of:

  • Adding greenhouse gas (GHG) PALs;

  • Eliminating certain GHG only sources from PSD;

  • Adding the grandfathering provisions for the 2012 annual primary PM2.5 NAAQS and the 2015 8-hour ozone NAAQS; and

  • Incorporation a correction to the definition of “regulated NSR pollutant.”

The principal effect of this action is to update the Mississippi PSD provisions related to greenhouse gases and incorporate changes, add the 1997, 2006 and 2012 PM2.5 standards and the 2015 8-hour ozone standard.

North Dakota

On July 28, 2017, EPA proposed to approve a number of changes to the North Dakota NSR rules to update them to reflect current requirements. 82 Fed. Reg. 35153. Changes proposed to rule 33–15–14–02.5.a include:

  • Adding PM2.5 significant impact levels to 0.3 ug/m3 annual and 1.2 ug/m3 24-hour;

  • Revised SO2 1-hour significance level to 7.8 ug/m3 and NO2 1-hour significance level to 7.5 ug/me

  • Revoke the PM10 annual significant impact level because the PM10 annual NAAQS was revoked

South Carolina

On August 10, 2017, EPA gave direct final approval to updates to the South Carolina New Source Review program submitted by the Department of Health and Environmental Control (DHEC) on July 18, 2011, April 10, 2014, August 12, 2015 and January 20, 2016, as amended by withdrawals from consideration of certain aspects in letters dated December 20, 2017 (fugitive emissions) and June 27, 2017 (changes in definition of net emissions increase). 82 Fed. Reg. 37299 (Aug. 10, 2017). The approved changes affect both SC DHEC Reg. 61-62.4, Standard No. 7 – PSD and Standard 7.1 – NNSR. The changes include:

  • Updating the DHEC NSR program to include changes required by the Phase 2 Rule (70 Fed. Reg. 71612 (Nov. 29, 2005). This change recognizes nitrogen oxides as an ozone precursor for PSD purposes; changing the NNSR rule “major source” thresholds and significant emission rates, and revising criteria for offsets and offset ratios.

  • Updating the DHEC PSD program to include changes required by the PM2.5 Implementation Rule provisions for condensable particulate matter (promulgated October 25, 2012 )

The specific changes made and approved were as follows:

  • Definitional changes: updated definitions in Standard 7, paragraphs (q)(2) and (3) on public participation, (r)(4) source obligation, and (w)(1) permit rescission.

  • Adopting threshold definitions in Standard 7.1 for “serious” and “extreme” nonattainment areas.

  • Adopting the change to Standard 7 definition of “regulated NSR pollutant” at paragraph (b)(44) to be consistent with the condensable rule.

  • Adjusting the definition of “baseline actual emissions” and “projected actual emissions” in both Standard 7 and Standard 7.1 to include emissions associated with malfunctions.

  • Minor definitional changes for consistency with the federal rules: (b)(5)(i)(b), (b)(34)(vi)(c) (baseline area, net emissions increase), (i)(8)(ii) and (i)(10) exemptions, (m)(1)(a) air quality information, (n)(1) source information, (u)(4) class III areas, and certain PALs provisions.

On August 17, 2017, EPA proposed to approve changes to South Carolina’s minor NSR program submitted by DHEC on October 1, 2007, July 18, 2011, June 17, 2013, August 8, 2014, January 20, 2016 and July 27, 2016. 82 Fed. Reg. 39083. In this action, EPA stated it would not act on Reg. 61-62.1, Section II, paragraph G.6 “Emergency Provisions” nor changes to the minor source permitting provision submitted in the August 8, 2014 submittal or a number of other provisions. Please see 82 Fed. Reg. at 39083-84 for a list of what EPA did not do. EPA proposed to approve the following:

  • Reg. 61-62.1, Section II.A. “Construction Permits.” The October 1, 2007 proposal adds allowed preconstruction activities (A.1.d) for true minor sources, adds a requirement for written notification to the Department marking the commencement of construction and startup, and requires compliance with all terms, limits, and conditions of construction permits, adds time constraints for the validity of construction permits, and clarifies language.

  • Added general preamble language to Section II that permits must be followed and that a source’s permit status may change is new requirements become applicable.

  • Clarifies that allowed preconstruction activities are “extremely limited in nature and do not include construction of that actual process unit itself.” Also, the allowance for pouring concrete foundations is limited to sources that do not require a federally enforceable limit to be minor and for which no other condition would prohibit initiation of construction (e.g., PSD, NNSR and NESHAP major sources).

  • Reg. 61-62.1, Section II.B, clarifies that the boiler and space heater exemption limited to “virgin fuels,” adds an exemption for up to 10 MMBtu/hr virgin natural gas, modifies the hours for testing and maintenance of exempted emergency generators, expands paragraph B.2.h to exempt more sources with emissions less than 1 lb/hr PTE of sulfur dioxide, nitrogen oxides, or carbon monoxide (later changed to 5 tons/year), provides that exemption does not relieve a source from any other requirements, and sets up a notification process for sources seeking exemptions under paragraphs B.2 or B.4. A later submittal added a requirement that sources keep records of their exemption demonstrations and claims.

  • Reg. 61-62.1, Section II.D, general construction permits.

  • Reg. 61-62.1, Section II.E, “Synthetic Minor Construction Permits.” This section renumbered former II.H to II.E, adds paragraph E.3 to list required synthetic minor permit conditions.

  • Reg. 61-62.1, Section II.F. A bit beyond the NSR program, EPA also proposed to approve Section II.F, “Operating Permits.”

  • Reg. 61-62.1, Section II.G, “Conditional Major Operating Permits.” This section provides a mechanism for sources to restrict PTE below major source thresholds, provides that sources obtaining synthetic minor construction permits will receive conditional major operating permits, allows sources to operate while DHEC processes renewal applications and numerous other changes.

  • EPA proposed to approve changes to Section II.H, operating permit renewal requestes, II.I, registration permits (for true minors), II.J, permit conditions, II.N public participation (to allow use of website in lieu of newspaper notification). Other sections were also addressed.


On August 28, 2017, EPA gave final approval to changes to Virginia’s major NSR programs. 82 Fed. Reg. 40703. Approved changes to 9VAC5 include:

  • Allow the use of a 10-year lookback period to calculate pre-change emissions for sources other than electric utility steam generating units (EGUs);

  • Allow the use of different lookback periods for different regulated NSR pollutants;

  • Extend the effective period for plantwide applicability limits (PALs) to 10 years; and,

  • Allow replacement units to be treated as existing units, and thus provide the ability to use baseline actual and projected actual emissions when determining applicability.

EPA stated its preliminary conclusion that the preconstruction activities allowed by the proposed changes were consistent with federal law. EPA also determined, in light of an opinion from the Virginia attorney general that the Virginia Audit Privilege and Immunity Laws did not provide privilege protection to documents required by federal law nor provide immunity where inconsistent with federal law, that the laws, as thus construed, do not preclude grant of approval

As a result of these changes, EPA “fully approved” the prior limited approval of the Virginia DEQ PSD and NNSR programs.

Nonattainment SIP actions that change scope, but not substance, of NNSR program

EPA issued the following proposals and final actions to approve existing NSR provisions as satisfying nonattainment area plan requirements:


On September 8, 2017, EPA approved the 2006 PM2.5 moderate nonattainment area plan for the Fairbanks North Bureau. 82 Fed. Reg. 42457.


EPA gave direct final approval of Connecticut’s NSR program for the 2008 ozone NAAQS for the Greater Connecticut ozone nonattainment area and the Connecticut portion of the New York-N. New Jersey-Long Island, NY–NJ–CT ozone nonattainment area. 82 Fed. Reg. 37819 (Aug. 14, 2017) (direct final).


EPA proposed to approve Iowa’s nonattainment plan for the Muscatine SO2 nonattainment area. 82 Fed. Reg. 40086 (Aug. 24, 2017) (proposed rule)

New Hampshire

EPA proposed approval of Central New Hampshire SO2 nonattainment area plan NSR provisions in ENV-A 618. 82 Fed. Reg. 45242 (Sept. 28, 2017) (proposed rule).

New York

On September 14, 2017, EPA proposed to approve New York’s NNSR program certification as adequate to satisfy the 2008 8-hour ozone NAAQS. 82 Fed. Reg. 43209. In its certification, NYSDEC stated that since New York is in the Ozone Transport Region, NNSR applies statewide for emissions of VOC and NOx from new major facilities and modifications and these changes are subject to 6 NYCRR Part 231. EPA gave final approval of the NNSR certification on December 12, 2017. 82 Fed. Reg. 58342.


EPA proposed and finalized approval of changes to R307-420 and R307-403-6. 82 Fed. Reg. 32517 (July 14, 2017) (proposal); 82 Fed. Reg. 46417 (Oct. 5, 2017) (final).

  • R307-420 maintains the offset provisions for the NNSR program in Salt Lake and Davis Counties after they are redesignated to attainment for ozone and makes the NOx offset requirements more stringent. R307-420 also is revised to be consistent with the permit provisions in R307-403.

  • R307-403-6 is revised to conform definitions to EPA’s rules.

Infrastructure SIP actions

Infrastructure SIP approvals generally confirm that the state or local program authority has in place general provisions allowing proper administration of the Clean Air Act program. While necessary for a fully effective program, EPA generally does not discuss NSR program details in these actions.

Colorado, 2010 SO2 and 2012 PM2.5 NAAQS. 82 Fed. Reg. 39030 (Aug. 17, 2017) (final rule)

Florida, 2010 1-hour nitrogen dioxide NAAQS. 82 Fed. 37310 (Aug. 10, 2017) (direct final rule)

Idaho, 2012 PM2.5 Annual NAAQS. 82 Fed. Reg. 42772 (Sept. 12, 2017) (proposed rule)

Indiana, 2012 PM2.5 NAAQS. 82 Fed. Reg. 41379 (Aug. 31, 2017) (proposed rule)

Kentucky, 2012 PM2.5 NAAQS. 82 Fed. Reg. 37012 (Aug. 8, 2017) (final rule)

North Carolina, 2008 8-hour Ozone NAAQS. 82 Fed. Reg. 37371 (Aug. 10, 2017) (proposed rule)

Rhode Island, 2010 Nitrogen Dioxide and 2010 Sulfur Dioxide NAAQS. 82 Fed. Reg. 41197 (Aug. 30, 2017) (proposed rule)

South Carolina, 2010 1-hour NO2 interstate transport. 82 Fed. Reg. 38646 (Aug. 15, 2017) (proposed rule)


Several trends are discernible in this state program update. First, it appears that the pace of state program approvals has picked up. This is consistent with Administrator Pruitt’s emphasis on greater cooperation with the states and long-deferred federal action on state plan submittals has been a source of friction with state and local programs. Second, the approvals are beginning to show a trend away from the former pattern of only “more stringent” program submittals being accepted and approved. In this round, South Carolina gained approval for a carefully crafted program freeing some sources from full minor NSR procedures. Most significantly, Arkansas gained approval for increasing its de minimis NSR program to the PSD “significant emission rates” for many pollutants, a significant change from past practice. The Arkansas action likely provides a template for the type of analysis that other state and local programs could take to justify steps increasing flexibility in the minor NSR program context.

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