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OAR Box 1781 

Prepped by Ollie Stewart 

Document Number: 

76) IV-A-9 

Docket Number: 

A-90-37 

Printed 10/29/2008 10:46:21 AM Sheet 76 of 142 
Comment: 

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^OV 2 2 2002 

EPA A!^ DOCKET j 

Some commenters argued that EPA must prepare an analysiFof"the environmental 

impacts of the rule before issuing it in final form. 

Response: 

As we have previously noted, a common-sense analysis of the effect of these rules shows 

they will not result in an increase in emissions. Nevertheless, EPA conducted an analysis of the 

anticipated environmental impacts from the final rule, "Supplemental Analysis of the 

Environmental Impact of the 2002 Final NSR Improvement Rule" (DATE). Although the 

analysis was not used in formulating our rule, it provides further support for EPA's view that the 

rule will be environmentally beneficial. This analysis is available in the docket. 

Overall, the analysis shows that the final rule will result in emissions reductions 

compared to the current NSR rules. Because the NSR Improvement rule does not significantly 

alter the rules for coal fired power plants, and does not affect the NSR provisions for new sources 

and new units, its overall impact is relatively small. The reductions will primarily reduce levels 

of criteria pollutants like ozone. These reductions will result in health and welfare benefits such 

as lower incidences of premature mortality, asthma, and other respiratory diseases and damage. 

Smaller reductions in hazardous air pollutants, ozone depleting substances, and other pollutants 

will also occur. 

Specifically, for each of the rule's five provisions, the analysis concludes the following: 

- Plantwide Applicability Limits (PALs) will result in tens of thousands of tons per 

year of Volatile Organic Compounds (VOC) reductions from just three industrial 

categories where PALs are likely to be used heavily. Overall reductions will be 

greater because it is likely that PALs will be adopted for more source categories 

and pollutants than those analyzed. 

— The Clean Unit Test will be environmentally neutral for most sources, but some 

sources will control earlier or more extensively than under current rules, and a net 

benefit will result. The amount of this benefit is uncertain nationally, but will 

likely result in important reductions in individual cases, such as the estimated 

9,300 ton per year VOC reduction seen in one example. 

— The Pollution Control Project Exclusion will lead to a small increase in the 

number of environmentally beneficial projects because it removes NSR barriers to 

such projects. The amount of this benefit is uncertain nationally, but will likely be 

relatively small. 

- The change in actual emissions baseline will not have a significant environmental 

impact. A small number of existing emissions units may get higher baselines 
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under the final rule and potentially avoid NSR, but other units may get lower 

baselines due to the requirement to adjust the baseline downward to account for 

any new emissions limits at that unit. New sources, new units, electric utilities, 

and many modified sources will be completely unaffected by the baseline change, 

so its impact is small. 

- The change to an actual-to-projected-actual test will have a net environmental 

benefit, but a relatively small one. The benefit stems from two things: 

(1) removal of the NSR program's current incentive to keep actual emissions high 

before making a change, and (2) removal of NSR's barriers to projects that will 

actually reduce emissions. The amount of this benefit nationally is uncertain. 

New sources, new units, electric utilities, and modifications that actually result in 

increased emissions will be completely unaffected by this change, so its impact is 

small. Under the current rule, virtually all other sources take permit limits to 

avoid NSR. The analysis concludes that the benefits from this aspect of the 

program are likewise unaffected because such sources must still assure that actual 

emissions do not significantly increase. 

Because four of the five provisions result in environmental benefits, and the other provision has 

no significant effect, the analysis concludes that the overall effect of the rule will be a net 

environmental benefit.