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2008-06-20_REVISION - C1980007
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2008-06-20_REVISION - C1980007
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Last modified
8/24/2016 3:33:23 PM
Creation date
6/23/2008 9:47:20 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
REVISION
Doc Date
6/20/2008
Doc Name
Request of Rocky Mountain Clean Air Action for Formal Hearing on the Proposed Decision
From
EarthJustice
To
DRMS
Type & Sequence
TR111
Email Name
TAK
Media Type
D
Archive
No
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Significant Deterioration PSD permit. Contrary to the Forest Service's claim, the Project's <br />methane drains are stationary sources subject to this requirement. <br />Under Colorado air quality regulations, which have been approved by the EPA and <br />incorporated into a State Implementation Plan ("SIP") (and are thus federally enforceable), any <br />stationary source that emits more than 250 tons per year "of any air pollutant subject to <br />regulation under the Federal Act" falls under PSD permitting requirements, including the <br />requirement that Best Available Control Technology ("BACT") be utilized to keep all emissions <br />in check. See Air Quality Control Commission ("AQCC") Regulation Number 3, Part D <br />§ II.A.25.a.(ii). The Project will concededly emit far more than 250 tons per year of methane. It <br />is therefore a major source for PSD purposes and cannot be approved until it obtains a PSD <br />perm it.24 <br />24 This conclusion is bolstered by the Colorado Air Quality Control Act (CRS 25-7), the <br />stated intent of which is that: <br />In order to foster the health, welfare, convenience, and comfort of the inhabitants of the <br />state of Colorado and to facilitate the enjoyment and use of the scenic and natural <br />resources of the state, it is declared to be the policy of this state to achieve the maximum <br />practical degree of air purity in every portion of the state, to attain and maintain the <br />national ambient air quality standards, and to prevent the significant deterioration of air <br />quality in those portions of the state where the air quality is better than the national <br />ambient air quality standards. To that end, it is the purpose of this article to require the <br />use of all available practical methods which are technologically feasible and <br />economically reasonable so as to reduce, prevent, and control air pollution throughout the <br />state of Colorado; to require the development of an air quality control program in which <br />the benefits of the air pollution control measures utilized bear a reasonable relationship to <br />the economic, environmental, and energy impacts and other costs of such measures; and <br />to maintain a cooperative program between the state and local units of government. It is <br />further declared that the prevention, abatement, and control of air pollution in each <br />portion of the state are matters of statewide concern and are affected with a public <br />interest and that the provisions of this article are enacted in the exercise of the police <br />powers of this state for the purpose of protecting the health, peace, safety, and general <br />welfare of the people of this state. <br />See CRS 25-7-102. The Act also defines "air pollutant" broadly to include "any fume, smoke, <br />APPEAL OF E SEAM METHANE DRAINAGE WELLS PROJECT, APRIL 28, 2008 PAGE 38
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