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What are the resulting impacts on emissions associated with the changes? EPA's evaluation is that overall emissions will decline. Remember, the NSR program is a technology permitting program, not an emissions reduction program. All the impacted facilities are extensively regulated under thc Clean Air Act to protect public health and welfare. Emissions reductions will continue to occur under other Clean Air Act programs, including the National Ambient Air Quality Standards, the visibility/regional haze rule and the proposed Clean Air Interstate and mercury rules. In addition, North Carolina's emissions of N0x, S02 and mercury will continue to decline, thanks to the Clean Smokestacks Act. In 1996, EPA estimated that these improvements will mean 50% fewer sources would go through NSR. Doesn't that mean the changes will have an adverse impact on air quality? The number of times sources have to go through the permitting process is not a good measure of NSR benefits. EPA's analysis of the NSR reforms is that they will benefit the overall environment by improving energy efficiency without emissions increases. In addition, the NSR rule changes will provide regulatory certainty, administrative flexibility and permit streamlining. Even though a source may make a change without obtaining a new NSR permit, it does not mean that source is not covered by NSR or that NSR is reducing air emissions from the source. For example, a source that takes an emissions cap known as a Plantwide Applicability Limit (PAL) may avoid some future NSR permitting, but only in exchange for an agreement to cap its overall emissions under the NSR program. By so doing, it would reduce its emissions and also reduce the frequency of its NSR permit reviews. Conversely, requiring an NSR permit for some types of projects (e.g., those at clean units) can result in no or only trivial environmental benefits. The NSR rule is designed to streamline review in such cases. Likewise, requiring an NSR permit for some environmentally beneficial projects may deter some projects fromr going forward. In such instances, no permit is now recorded, but real environmental benefits are lost. The rules are designed to remove NSR barriers and promote these beneficial projects. If the rule allows facilities to freeze their emission levels for 10 years, doesn't that mean the EPA's NSR changes will not lead to air quality improvements? No, in fact, EPA's review shows that the changes made will provide a net benefit to air quality by removing current NSR barriers to environmentally beneficial projects and by removing incentives in the current NSR rules to keep pollution at high levels. It is important to understand that the NSR program was never designed to require facilities to reduce existing levels of pollution - that is not its purpose. NSR is designed to be triggered when a new facility is being built or when one is undergoing a major modification that could significantly increase emissions. NSR is a permitting process to review and control emissions increases, not a tool to require reductions. Sources' emissions fluctuate as part of the business cycle, as well as for other reasons. EPA's rule would resolve the uncertainty over what time period is truly representative of normal operations by allowing industrial sources to select any two-year period in the last 10 years - consistent with the business cycle. However, importantly, the baseline would have to be adjusted