In spring 2010, EPA finalized the Greenhouse Gas (“GHG”) Tailoring Rule, which states that large industrial facilities and projects will require an air permit for their GHG emissions beginning in 2011. On August 12, 2010, EPA issued two proposed rules to address concerns that some states will not be ready to issue permits on January 2, 2011. In the first rule, EPA proposes to find that 13 states — Alaska, Arizona, Arkansas, California, Connecticut, Florida, Idaho, Kansas, Kentucky, Nebraska, Nevada, Oregon, and Texas — have state implementation plans (SIP) that are “substantially inadequate” to meet CAA requirements. The plans are… Read more