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Abstract

January 1, 2011, marked the beginning of one of the most significant changes to the scope of New Source Review (NSR) rules since their enactment. As a result of greenhouse gases (GHGs) becoming a regulated pollutant under the Clean Air Act (CAA), the Environmental Protection Agency (EPA) determined that such pollutants must now be addressed as a part of Prevention of Significant Deterioration (PSD) reviews. Although no air quality analysis is required for such pollutants, sources must address best available control technology (BACT) for GHG emissions as a part of a complete PSD application.