This report presents a study of the Environmental Protection Agency’s (EPA’s) "top-down" policy for determining "best available control technology" (BACT) under the Clean Air Act’s Prevention of Significant Deterioration (PSD) program. In 1988 EPA established its "top-downt" BACT policy internally, without providing an opportunity for public comment. The purpose of this study is to document key technical, economic, and legal issues related to the top-down policy and to identify options to challenge or modify the policy or mitigate its impact on gas transmission engines.
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