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Abstract
The electric power generation industry is under an ever changing, ever increasing, ever tightening regulatory climate that requires consideration of Best Available Control Technologies (BACT) for any new or modified Prevention of Significant Deterioration (PSD) and Title V requirements.

In principle, carbon capture and storage (CCS) could provide reduction of greenhouse gases and therefore should be considered. However, since CCS is neither a proven commercial technology nor is it mandated (as of yet), it seems that requiring consideration now is confusing at best.

EPA guidance states that permit applicants and permitting authorities should consider all “available” GHG control options that have the potential for practical application to the source under consideration. The guidance further suggests that once permitting authorities gain experience with GHG BACT determinations, useful information on GHG permitting decisions will be presented.

The expression of regulatory decisions and permitting based on “future tense” terms makes planning, operational, and strategic decisions very difficult for the electric generation sector. This paper will endeavor to discuss and navigate specific details in the PSD requirements for power generation as they apply to carbon capture and storage.

Introduction
Under revisions to the Clean Air Act, beginning on January 2, 20101, any emission source that is required to obtain or modify a prevention of significant deterioration (PSD) or Title V permit must now consider greenhouse gases (GHGs) as an emission source. New major stationary sources or modifications under the Clean Air Act, new source review (NSR) and national ambient air quality standards (NAAQS) respectively, must obtain a permit under the PSD provisions. This means that power plants must now consider carbon dioxide (CO2) emissions as part of the permitting, construction, modification, and operations of the facility.

The process to determine what technologies are most applicable under PSD for a facility is known as best available control technology, or BACT, analysis.