On December 27, 2009 AGA submitted comments on EPA's Greenhouse Gas PSD Tailoring Proposed Rule. These comments note AGA's reasons that the proposed thresholds are still significantly too low both for sources in general and for natural gas burning sources in particular. The proposed threshold is based on a source’s “potential to emit” rather than actual emissions – making the artificial assumption that a furnace or boiler will operate constantly, 24 hours per day and 365 days per year. Finally, AGA's comments suggest steps EPA could take to allow additional time for the agency, states and the regulated community to adapt the PSD program to cope with the challenges of greenhouse gas emissions.
The cover letter, comments and attachments are posted under Environmental Comments and can be accessed by clicking here.