Now more than ever, as the economy continues to pick up steam, it is vitally important to reduce the barriers to economic growth. Nowhere is this more important than in the manufacturing sector.
In manufacturing, lengthy permitting processes can still be the death knell for projects that would otherwise expand operations and create new jobs. The Clean Air Act (CAA) has created delays so great that they kill some projects in their infancy before the permitting process has even started. While there has been bipartisan support for addressing permitting delays, Congress has only recently laid out a starting point from which improving efficiencies in permitting can be obtained.
In the meantime, the Environmental Protection Agency has stepped in to make some common sense reforms that were long overdue. Citing President Trump’s push to streamline regulatory permitting, the EPA recently announced its intention to clarify the permitting process under the New Source Review (NSR) analysis, which pertains to potential increased emissions at project sites.
Simply stated, the CAA’s NSR considers whether a manufacturer’s expansion of operations will result in a significant increase in emissions. Then, if there is a projected significant increase, the agency looks to see if there are any potential offsets to mitigate the net increase. Previously, the EPA calculated off-sets during the first step of the review process in such a way that it added unnecessary time and complexity.
As testimony in front of the House Energy and Commerce Committee revealed last year, going through the analysis could result in unnecessary delays even when there was no chance of a significant increase. In some cases, manufacturers decided to abandon projects altogether and put their resources elsewhere. The EPA’s proposed modification would address this problem by first asking whether there will be a significant increase in emissions, and if the answer is “no,” the project is allowed to move forward without a permit.