A full CEQA document will be prepared for the NSR amendments. Achieved in Practice Criteria Update Achieved in practice criteria for minor sources are included in the draft Part C document. Both of the documents should be available at the same time. EPA is also not comfortable with the inclusion of cost in the Part C document. In addition, EPA is not comfortable with the very narrow source categories specified in the document.
LAER policy calls for more open source categories that maximize technology transfer.
A third point is in the update process. LAER gets updated when new technology becomes available and meets certain criteria. For minor sources, the update process is completely different. Twelve months of commercial data followed by a public process and a Board hearing is required before staff can update the BACT Guidelines. A fourth point concerns the permit application date.