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Oregon’s Implementation of the Area Source NESHAPs

This presentation by Andy Ginsburg, Administrator of the Oregon Department of Environmental Quality, discusses the implementation of National Emission Standards for Hazardous Air Pollutants (NESHAPs) for area sources in Oregon. Key points include the health benefits, the need for compliance assistance, and the flexibility in response to small businesses. Challenges such as numerous unpermitted sources and limited resources are addressed, along with strategies like simple permits and general registrations. Lessons learned emphasize the importance of stakeholder engagement and clear communication throughout the process.

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Oregon’s Implementation of the Area Source NESHAPs

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  1. Oregon’s Implementation of the Area Source NESHAPs National Association of Clean Air Agencies Spring Membership Meeting May 17-19, 2010 Andy Ginsburg, Administrator Oregon Department of Environmental Quality

  2. Why Implement the Area Source NESHAPs? • Protect public health • Increase compliance • Provide assistance to • affected businesses • Ability to be flexible and responsive • Opportunity to prevent need for enforcement

  3. What Are The Barriers? • Many previously unpermitted sources • Many are small businesses • Revenue and staffing • Quality of some of the NESHAPs

  4. How is Oregon Implementing the Area Source NESHAPs? • Adoption triggers state (non-Title V) permit requirement • Simple and Standard Permits • Apply to individual sources • General Permits • Apply to multiple or categories of sources • Registration • Alternative to permitting

  5. New General ACDP Fee Classes for Area Source NESHAPs

  6. Fee Class Assignments for Area Source NESHAPs

  7. Registration –Alternative to Permitting • Incentive to go beyond compliance • Auto body shops - EcoBiz • Dry Cleaner certification

  8. www.ecobiz.org

  9. Lessons Learned • Anticipate business association objections • Don’t overestimate revenue • Simplify and clarify • Some work is unfunded • Push back at permitting stage • Keep legislators informed

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