A technical detail: What you quoted relates to hazardous air pollutants and MACT standards. EPA will be regulating GHGs as criteria pollutants and applying BACT standards. Even so, you are 100% correct on where this is headed legally.
The threshold for regulation of criteria pollutants under the CAA is 100 or 250 tons/year, but the regulations proposed today use a threshold of 25,000 tons/year. Using a 250 tpy threshold would require 6.1 million business to get federal operating permits. By changing the threshold, only about 14,000 permits will need to be issued.
EPA doesn’t have the authority to change the threshold that was mandated by the Clean Air Act legislation, but they are going to try.
I spent some time in greenie-blog-land this evening. It seems the greens are ecstatic that CO2 emissions are down 9% in 2009 due to the economic downturn. The cheerleading goes like this: We are already halfway to the GHG reduction goal of 20% by 2020! We can do this and it’s going to be EASY! Go green!
Thanks, can’t unpush that post button.