U.S. Environmental Protection Agency’s January 25 change to its “once in always in” policy will allow facilities that have historically been regulated as “major sources” of hazardous air pollutants to be reclassified as “area” sources if they have reduced their potential to emit to below major source thresholds. This is important because companies that are no longer regulated as major sources could see significant cost savings. Husch Blackwell has prepared a list of questions to help facilities evaluate possible benefits from this policy change, as well as other resources including a summary of affected emission standards and a look back at the regulatory language EPA previously proposed to implement a similar change in policy. Review the complete materials on Husch Blackwell’s website.
