PO Box 15004, Flagstaff, AZ 86011-5004
Phone: (928) 523-0526
Fax: (928) 523-1266 Andy.Bessler@nau.edu
NTAA Air Topics:
Prevention of Significant Deterioration (PSD)
Overview What Does PSD Require?
Prevention of Significant Deterioration (PSD) applies to new major sources or major modifications at existing sources for pollutants
where the area the source is located is in attainment or unclassifiable with the National Ambient Air Quality Standards (NAAQS). It
requires the following:
Installation of the "Best Available Control Technology (BACT)"
Air quality analysis
Additional impacts analysis
What is PSD's Purpose?
PSD does not prevent sources from increasing emissions. Instead, PSD is designed to:
Protect public health and welfare
Preserve, protect, and enhance the air quality in national parks, national wilderness areas, national monuments, national
seashores, and other areas of special national or regional natural, recreational, scenic, or historic value
Insure that economic growth will occur in a manner consistent with the preservation of existing clean air resources
Assure that any decision to permit increased air pollution in any area to which this section applies is made only after careful
evaluation of all the consequences of such a decision and after adequate procedural opportunities for informed public participation in the decision making process
What is BACT?
BACT is an emissions limitation which is based on the maximum degree of control that can be achieve. It is a case-by-case decision
that considers energy, environmental, and economic impact. BACT can be add-on control equipment or modification of the production
processes or methods. This includes fuel cleaning or treatment and innovative fuel combustion techniques. BACT may be a design,
equipment, work practice, or operational standard if imposition of an emissions standard is infeasible.
The RACT/BACT/LAER Clearinghouse (RBLC) database contains information on what has been required as BACT in air permits.
What is an Air Quality Analysis?
The main purpose of the air quality analysis is to demonstrate that new emissions emitted from a proposed major stationary source or
major modification, in conjunction with other applicable emissions increases and decreases from existing sources, will not cause or
contribute to a violation of any applicable NAAQS or PSD increment.
Generally, the analysis will involve (1) an assessment of existing air quality, which may include ambient monitoring data and air
quality dispersion modeling results, and (2) predictions, using dispersion modeling, of ambient concentrations that will result from
the applicant's proposed project and future growth associated with the project.
Class I areas are areas of special national or regional natural, scenic, recreational, or historic value for which the PSD regulations
provide special protection. The Federal Land Manager (FLM), including the State or Indian governing body, where applicable, is
responsible for defining specific Air Quality Related Values (AQRV's) for an area and for establishing the criteria to determine
an adverse impact on the AQRV's. If a FLM determines that a source will adversely impact AQRV's in a Class I area, the FLM may
recommend that the permitting agency deny issuance of the permit, even in cases where no applicable increments would be exceeded.
However, the permitting authority makes the final decision to issue or deny the permit.
What is PSD Increment?
PSD increment is the amount of pollution an area is allowed to increase. PSD increments prevent the air quality in clean areas from
deteriorating to the level set by the NAAQS. The NAAQS is a maximum allowable concentration "ceiling." A PSD increment,
on the other hand, is the maximum allowable increase in concentration that is allowed to occur above a baseline concentration for
a pollutant. The baseline concentration is defined for each pollutant and, in general, is the ambient concentration existing at the
time that the first complete PSD permit application affecting the area is submitted. Significant deterioration is said to occur when
the amount of new pollution would exceed the applicable PSD increment. It is important to note, however, that the air quality cannot
deteriorate beyond the concentration allowed by the applicable NAAQS, even if not all of the PSD increment is consumed.
What Additional Impacts Analysis are Required?
The additional impacts analysis assesses the impacts of air, ground and water pollution on soils, vegetation, and visibility caused
by any increase in emissions of any regulated pollutant from the source or modification under review, and from associated growth.
Associated growth is industrial, commercial, and residential growth that will occur in the area due to the source.