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ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION

DIVISION OF AIR QUALITY – AIR PERMITS PROGRAM

PRE-APPROVED EMISSION LIMIT APPLICABILITY NOTICE

Re: New Air Quality Control Regulations & their effect on Pre-Approved Emission Limits (PAELs)

The Alaska Department of Environmental Conservation recently made some significant changes to 18 AAC 50, the Air Quality Control Regulations. Some of these changes have an effect on the Pre-Approved Emission Limits (PAELs) in 18 AAC 50.230 that facilities use to avoid the need for a Title V Permit. As a result of those changes it is possible that some of the PAELs (previously known as PALs - Pre Approved Limits) may no longer be required for some facilities. The department recently also concluded a public comment period concerning fixed fees for certain permit and compliance activities. The fixed fee rulemaking will result in an increase in fees paid by PAEL holders for annual compliance reviews. If some of your facilities no longer are required to abide by a pre-approved emission limit, the increased fees may be avoided.

Enclosed with this notice is a Pre-Approved Emission Limit Applicability Guide. By following the guidance and instructions in this sheet, you can verify whether or not a PAEL must be maintained for a facility. Also attached is EPA guidance relating to standby or emergency generators. In the past, the State of Alaska rules for calculating potential to emit of sources did not allow DEC to take the reduced operating hours of emergency generators into account when determining whether a permit or permit avoidance document would be required at a facility. This has now changed with the new rules effective October 1, 2004.

If you determine that some of your facilities, based on current usage and installed electrical generating capacity, no longer require permit avoidance documents, you may request that the Pre-Approved Emission Limits for those facilities be rescinded. More details are in the attached Pre-Approved Emission Limit Applicability Guidance. If you have any questions, please do not hesitate to contact the department at (907) 465 5100.

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