The new PM 2.5 particulate standard and more stringent ozone standard will evolve into regional compliance strategies and lower emission limits. The federal land managers responsible for our national parks and wilderness preserves have increased authority to intervene in new-source permitting. In recent years some of the most substantive comments and strongest objections to new-source permits have come from parks authorities. This past summer was the worst on record for air pollution in the Great Smokey Mountains National Park as a result of the hot, dry conditions. Although most emission reductions will have to come from power plants and automobiles, the air-pollution levels of last summer are bound to result in more stringent permitting criteria.
Regulators have nearly absolute authority in the permitting process.
In a recent minimill permitting process, a regulator identified several control technologies that he wanted to see installed, even though they had never been employed at a steel mill. The applicant had to make a significant effort to address technological applicability and costs and demonstrate to the agency that these techniques weren't applicable. We as an industry have an increased need and responsibility to document the environmental performance of these new processes and instruct the regulators. These are not easy tasks. Even on evolutionary EAF changes, performance is more variable than expected.