What Is “Best Available Control Technology”?
Best available control technology (BACT) is a pollution control standard mandated by the Clean Air Act:
…an emission limitation based on the maximum degree of reduction of each pollutant subject to regulation under this Act emitted from or which results from any major emitting facility, which the permitting authority, on a case‐by‐case basis, taking into account energy, environmental, and economic impacts and other costs, determines is achievable for such facility through application of production processes and available methods, systems, and techniques, including fuel cleaning, clean fuels, or treatment or innovative fuel combustion techniques for control of each such pollutant.
The USEPA determines what air pollution control technology will be used to control a specific pollutant to a specified limit. When a BACT is determined, factors such as energy consumption, total source emission, regional environmental impact, and economic costs are taken into account. It is the current EPA standard for all polluting sources that fall under the New Source Review (NSR) and PSD permitting guidelines, and is determined on a case‐by‐case basis. The BACT standard is significantly more stringent than the reasonably available control technology standard but much less stringent than the lowest achievable emissions rate standard (U.S. EPA, 2016a).
Reasonably Available Control Technology
Reasonably available control technology (RACT) is a pollution control standard created by the EPA and is used to determine what air pollution control technology will be used to control a specific pollutant to a specified limit. RACT applies to existing sources in areas that are not meeting national ambient air quality standards on controlled air pollutants and is required on all sources that meet these criteria. The RACT standard is less stringent than the BACT.
Lowest Achievable Emissions Rate
The lowest achievable emissions rate (LAER) is used by the EPA to determine if emissions from a new or modified major stationary source are acceptable under SIP guidelines. LAER standards are required when a new stationary source is located in a non‐attainment air‐quality region (see Figure 4.14). It is the most stringent air pollution standard above the best available control technology and reasonably available control technology standards.
Life Cycle‐Based Environmental Law
Life cycle concepts are increasingly becoming a part of environmental regulation, especially those involving GHG emissions. Now LCA is often used in writing about carbon accounting. In these times of heightened concern over climate change, individuals, organizations, and governmental agencies alike are eager to measure the release and impact of GHGs. For example, a variety of governmental agencies are developing approaches for regulating the emissions of GHGs associated with the production and use of fuels. As an example, the Energy Independence and Security Act (HR 6) of 2007 (EISA 2007) aims to: move the United States toward greater energy independence and security; increase the production of clean renewable fuels; protect consumers; increase the efficiency of products, buildings, and vehicles. States are also implementing GHGs emission regulation (USEPA 2010). For example, California Global warming Solutions Act of 2006 resulted in regulations that establish a limit for life cycle GHG emissions of transportation fuels. Both the California low‐carbon fuel standard and Section 526 of EISA require a life cycle evaluation of the GHG emissions of transportation fuels and this is becoming a common approach to considering GHG emissions (Allen et al. 2009).
Life Cycle Best Control Technology
A number of quantitative tools are emerging that enable life cycle assessments and analyses, and subsequently provide guidance on selecting best available control technologies for PSD, NPDES, and other environmental permitting processes. Many of our environmental laws are based on risk frameworks. Now, the life cycle–based best control technology decisions in environmental permitting processes are made that incorporate not only health and environmental but also the economic and societal impacts. Next, we present a case study on BACT for a power‐generating facility.
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