In the world of the Clean Air Act (CAA), few topics elicit more controversy than new source review (NSR). Okay, perhaps “climate change” actually takes top billing, but NSR is probably next in line. After all, NSR was the first program the U.S. Environmental Protection Agency (EPA) used to regulate greenhouse gases from “stationary sources,” those power plants and industrial facilities now responsible for just under half of the greenhouse gas emissions in the United States. NSR generally refers to both the Prevention of Significant Deterioration (PSD) program and the nonattainment NSR program because the applicability provisions of both are similar—both require facilities to consider installing new emission controls when making other major modifications.
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