EPA Releases New PAL Guidance February 19, 2020 | Eric L. Hiser
On February 13, 2020, EPA Assistant Administrator Anne Idsal released a draft “Guidance on Plantwide Applicability Limitation Provisions Under the New Source Review Regulations” (Draft PAL Guidance) for public comment. The Draft PAL Guidance addresses concerns about when EPA or state permitting authorities should use the mandatory and discretionary permit reopening and provides additional guidance on PAL expiration and termination, the so-called PAL “ratchet” upon renewal, monitoring and data substitution, and calculation of baseline actual emissions for replacement units. The Draft PAL Guidance also provides some example PAL contribution and distribution calculations. Comments are due to EPA by March 16, 2020 and may be submitted on the agency website or by emailing EPA.