This webinar will include presentations on:

•  Common Control Determinations for Stationary Sources and Major Sources (interpretations issued on April 30 and October 16, 2018, and July 12, 2019)

•  Interpretation of “Adjacent” for Stationary Sources and Major Sources (draft policy issued on September 4, 2018)

•  Permitting Issues for Stationary Sources Located in Serious (Reclassified from  Moderate) Ozone Non-attainment Areas (final Rule published on August 23, 2019)

•  Reclassification of Major Sources as Area Sources Under §112 of the CAA (proposed rule published on July 26, 2019)

The memorandums on common control provide EPA’s refined, but narrowed, interpretation on common control criterion when determining if two or more stationary sources should be combined for permitting purposes.    

The draft guidance on adjacency provides EPA’s current interpretation on the term “adjacent” when determining if two or more stationary sources should be combined for permitting purposes.   

The final rule on reclassifying moderate non-attainment areas for 2008 ozone NAAQS to serious areas with more stringent requirements create permitting challenges for stationary sources and major sources.

The proposed rule on reclassifying major sources as area sources would incorporate the plain language reading of “major source” and “area source” definitions under §112 of the CAA.