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Q&A on New Source Review <br /> <br />Who does this rule impact? <br />The rule covers a number of entities, including electric utilities, pulp and paper mills, chemical <br />manufacturing, printing operations and pharmaceutical companies and many other facilities that <br />operate boilers. Any source that makes a modification (which varies by pollutant and by the <br />area's attainment status) could be impacted by this rule. <br /> <br />Did EPA make these NSR changes without analyzing the impact on public health and the <br />environment? <br />No. In fact, EPA has evaluated the impact of the changes to the NSR program and found that <br />these improvements will reduce overall emissions by: <br /> · eliminating regulatory barriers that stand in the way of environmentally beneficial <br /> projects at existing plants; <br /> · removing counterproductive incentives that encourage facilities to maintain their <br /> emissions as high as legally allowed; and <br /> · establishing regulatory incentives for sources to decrease emissions. <br /> <br />Don't the EPA's changes pre-empt state programs? <br />No. EPA believes that the changes will significantly improve the NSR program and included the <br />changes in the base NSR program - as has been EPA's consistent practice. The agency has <br />encouraged states to adopt these changes in their own programs. <br /> <br />Why are you asking the state to adopt the federal rule? Shouldn't North Carolina's <br />environmental regulators have the ultimate say in how the NSR rules are carried out? <br />States are required to implement the NSR rule, but EPA has given flexibility to the states in how <br />they do so. Adopting any alternative to the federal rule would adversely impact the state's <br />economic competitiveness. <br /> <br />North Carolina's proposed Option 3 increases both the frequency and complexity of air <br />permitting for both the sources and the state. Sources would be required to accept permit limits <br />on the amount they could manufacture based on what they produced in the recent past. Changes <br />in market conditions that result in increased demand would require permit changes even if the <br />plant, and its pollution control equipment, was designed to accommodate the increase. This <br />limits the flexibility that sources in North Carolina need to respond in the global marketplace. <br /> <br />In recent years, North Carolina's manufacturing sector and other business sectors have struggled. <br />Companies have closed, and thousands have lost jobs. Additional regulations - above and <br />beyond those required by our neighboring states - will have a negative effect on our state's <br />business climate. <br /> <br />Given a choice between a state that has adopted the federal NSR rules in their entirety and North <br />Carolina, it's very likely that businesses will choose the lo~ation that provides the most <br />flexibility and certainty. North Carolina should ensure the regulatory flexibility and certainty by <br />adopting the federal rule. <br /> <br /> <br />