in Mississippi

GREENHOUSE GAS AND CLIMATE CHANGE
Greenhouse Gas
In 2010, the EPA published its final rule to control green house gas emissions (GHGs) from
stationary sources under the two major CAA permitting programs. (75 Fed. Reg. 31514)
Beginning January 2, 2011, GHG became a regulated pollutant and thus became subject to the
air pollution permitting programs.
Mississippi has adopted the “Tailoring Rule” for GHG’s which set thresholds for emissions that
define when permits under the New Source Review Prevention of Significant Deterioration
(PSD) and Title V Operating Permit programs are required for new and existing industrial
facilities. The tailoring rule increases the GHG applicability threshold so that only the larger
emitting sources will be subject to regulation.
To be subject to GHG permitting, facility emissions must trigger GHG’s on both a mass and a
Global Warming Potential basis. GHG’s refer to a group of six pollutants: Carbon Dioxide,
Methane, Nitrous Oxide, Hydro Fluorocarbons, Per Fluorocarbons, and Sulfur Hexafluoride.
According to MDEQ, the agency will implement the GHG regulations in two initial phases:
PSD Construction Program
Step 1 (January 2, 2011 – June 30, 2011)
Only sources currently subject to the PSD permitting program (i.e., those that are newly
constructed or modified that significantly increases emissions of traditional pollutants) could be
subject to PSD for GHG emissions. PSD permitting for GHGs would be required if emissions
exceed the significant threshold of 75,000 tpy total GHG on a CO 2 equivalent (CO 2 e) basis and
have a net mass increase (>0 tpy) of total individual GHGs. If MDEQ issued a facility a PSD
permit prior to January 1, 2011 and that facility has not begun actual construction until after
January 1, 2011, the facility does not have to go back and include GHGs in their PSD permit.
Step 2 (July 1, 2011 to June 30, 2013)
PSD permitting can now be triggered if GHGs exceed the major source threshold for GHGs even
if they do not exceed the PSD permitting thresholds for any other pollutant (i.e. PSD major if
emissions are 100,000 tpy CO 2 e or more and 100/250 tpy GHGs on a mass basis). Modifications
at existing major facilities that increase GHG emissions by at least 75,000 tpy of CO 2 e will be
subject to permitting requirements, even if they do not significantly increase emissions of any
other pollutant. If MDEQ issues a facility a permit prior to July 1, 2011, and that facility has
NOT begun “actual” construction, they must address GHGs before beginning construction.
Title V Operating Program
Step 1 (January 2, 2011 – June 30, 2011)
Only sources currently subject to the program (i.e., newly constructed or existing major sources
for a pollutant other than GHGs) would be subject to Title V requirements for GHGs. Sources
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