PFPI-BiomassIsTheNewCoal-April-2-2014

All three facilities went through a BestAvailable Control Technology analysis (BACT,described further below), meaning that theiremissions are relatively well-controlledcompared to other facilities of their type.However, emissions from the biomass plantEven when a biomass plant is using bestavailable control technology, emissions ofkey pollutants exceed those of moderncoal and gas plants.exceed those from the fossil fueled plants for all pollutants except sulfur dioxide, for which biomassemissions exceed gas, but not coal. Relative to the coal plant and the gas plant, respectively,allowable emissions at the biomass plant are126% and 5639% for carbon monoxide; 157% and2015% for nitrogen oxides; 197% and 863% for filterable PM 10 ; 38% and 3514% for sulfurdioxide; and 655% and 1535% for volatile organic compounds. 18How the Clean Air Act regulates pollution from power plantsThe Clean Air Act is the main federal law regulating emissions from power plants and otherstationary source facilities. While the Clean Air Act can regulate any pollutant, the main pollutantsit governs are the so-called “criteria” pollutants (particulate matter, carbon monoxide, nitrogenoxides, sulfur dioxide, ozone, and lead); hazardous air pollutants (HAPs), the group of 187+pollutants that are considered especially toxic by EPA; and greenhouse gases, including CO 2 .A key regulatory tool in the Clean Air Act is the New Source Review (NSR) process, whichrequires new or modified stationary sources like power plants to obtain a preconstruction permitthat sets allowable pollution emission rates and other conditions of operation. 19 The restrictivenessof these permits varies, based on how much pollution a facility is anticipated to emit (larger sourcesare regulated more tightly than smaller sources) and the existing air quality in the area (facilitieslocated where air pollution already exceeds EPA’s health standards are more tightly regulated).Preconstruction permits can be issued according to one of three permitting subprograms underNew Source Review:The “Prevention of Significant Deterioration” (PSD) program applies to facilities of a certainsize located in areas that meet the National Ambient Air Quality Standards (NAAQS), thehealth standards that EPA sets for the criteria air pollutants PM, CO, NO x , SO 2 , ozone, andlead. While state air permitting agencies write these permits, they must do so inaccordance with EPA regulations, and EPA and the public may provide comments and inputon certain permits.18A potential but currently suspended permit revision filed in February 2014 seeks to regulate the facility under the major sourceboiler rule. If the plant is re-permitted as a major source for HAPs, allowable filterable PM emissions will decrease under themajor source MACT for bubbling fluidized bed boilers, from of 0.015 lb/MMBtu to 0.0098 lb/MMBtu (Gainesville RenewableEnergy Center. Initial Title V air operation permit application filed with Florida Department of Environmental Protection.February 10, 2014). This change would reduce permitted emissions from 89 tons to 58 tons of filterable PM per year, butfilterable PM emissions per MWh would still be 128% those from the coal plant.19New source review permits are “preconstruction permits,” and differ from Title V permits, which set out the terms by whichfacilities are expected to operate and meet the emissions limits specified in the NSR permit.18