Clean Air Act Policy Change: How the End of the ‘Once In, Always In’ Policy Could Impact Major Source Emitters

by | Feb 9, 2018

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On January 25, 2018, the EPA announced that it was withdrawing the “Once in, Always in” policy for the classification of major sources of hazardous air pollutants under section 112 of the Clean Air Act. With the new guidance, sources of hazardous air pollutants previously classified as “major sources” may be reclassified as “area” sources at any time, as long as the facility limits its potential to emit below major source thresholds. EPA’s change in policy also triggers a broader question about how facilities can best take advantage of their compliance systems to streamline their permitting and confirm applicable requirements to facilitate better business decisions.

Join Cority’s Ian Cohen and Arcadis’ Linda Kemp and Brad Micheel as they walk through what this policy change means for you and your business.

You will learn:

  • An overview of the ‘Once In, Always In’ policy
  • The difference between ‘Major Source’ and ‘Area Source’ classification
  • What this could mean for industry and how to prepare
  • How to understand compliance obligations and use them to drive business decisions


Ian Cohen, Product Marketing Manager, Cority
Ian Cohen, MS is the Product Marketing Manager responsible for Cority’s Environmental and Safety initiatives. Before taking this role, Ian was Cority’s Environmental Product Manager, where he was responsible for developing Cority’s Environmental Compliance and Data Management Suite. Prior to working with Cority, Ian was an environmental specialist at Florida Power & Light Company, a NextEra Energy, Inc., company, where he led the development, implementation, and management of various environmental management systems and programs. Ian is well versed in the development of enterprise environmental management information systems and is a subject matter expert in corporate sustainability, including program development, annual reporting and stakeholder communications. Ian earned a Bachelor of Science degree in Biology and a Master of Science in Environmental Science, both from The University of Tennessee at Chattanooga.

Linda Kemp, Arcadis Air Services National Practice Leader
Ms. Kemp has over 30 years of experience in environmental consulting, with more than 25 years focused on resolving air quality challenges facing our clients.  Her expertise includes emissions inventory development and quality assurance, New Source Review, Title V permitting, and minor new source review and permitting, compliance best practices, enforcement support and negotiations with regulatory agencies.  In addition, her experience has addressed more unique aspects of permitting, including development of process-specific emission factors, developing and implementing source testing programs for unusual processes and facilities, management of change effects on permitting, developing a chemical evaluation procedure to avoid permit exceedances, air toxics evaluations and potential community exposure considerations, and developing applicability determination and tracking programs.  Ms. Kemp has worked in a variety of industrial sectors, including mining, chemical, manufacturing, municipal, Federal, and aerospace.  Prior to joining ARCADIS, she owned and directed an environmental compliance firm for four years that specialized in air quality.  Ms. Kemp has authored and presented papers on environmental regulations, NEPA, air permitting, and source reduction strategies.  She has won client awards for outstanding service and professional association awards for environmental planning.

Brad Micheel, Principal Management Consultant, Arcadis
Mr. Brad Micheel has over twenty years of experience assisting clients with management of their environmental programs, including estimating emissions, developing compliance demonstration plans, and implementing management information systems for the tracking, monitoring, and reporting of business information. His areas of expertise include Title V and synthetic minor operating permits, Maximum Achievable Control Technology standards, Prevention of Significant Deterioration permitting, and state construction and operation permitting for companies around the world. Mr. Micheel has worked with companies in the aerospace, oil & gas, electric utility, cement, metals processing, agricultural and chemical industries, as well as with government and military operations. He has worked predominantly as a consultant; in addition, he has also worked for a leading environmental software company as well as an ethanol fuel company as their Corporate Permitting and Regulatory Compliance Manager. Mr. Micheel has a Bachelor of Science in Aerospace Engineering, a Masters of Science in Mechanical Engineering, and is a licensed Professional Engineer in South Dakota.


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