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Thursday, October 21, 2010 10:56:32 PM
I'm not sure about comparisons to cars and trucks, but I see that the Title V issue is now laid to rest.
Yes, that brings us back to state (as opposed to Federal) regulations regarding permitting. Based solely on the emissions data we have available, there is no reason to think JBI will be subject to the heightened scrutiny of major projects. As I have recognized before, that ultimate determination is left to the authority of the DEC, and we do not have all the data that is or will be before that agency. We are thus limited to the data that has been released. With that in mind, here is a DEC summary of the major vs. minor dichotomy that we have discussed in the past:
http://www.dec.ny.gov/permits/6244.html
Note that the thresholds in the DEC chart are set in TONS per year. The 5,677 lbs. of NOx you noted does not come anywhere close to those thresholds.
Yes, this is a summary, and should not be treated as all-inclusive. To date, however, I have not seen any substantiated basis for imposing heightened regulation. We have discussed previously the public hearing and comment requirements in the context of DEC classifications, so I will not go back into that now. Suffice it to say that the public hearing and comment requirements imposed on major projects are not imposed on minor projects (subject to exceptions).
I am not up to date on the board, so please let me know if I am missing some recent information. Sorry if it takes me some time to respond.
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