Would this rule need to be addressed in Title V operating permits?
Currently, the Mandatory Reporting of Greenhouse Gases Rule requirements do not have to be incorporated into a facility's Title V permit. For an explanation of why Title V permits are not impacted by this rule, please see Section II.S (Summary of Comments and Responses on Other Legal Issues) in the preamble.
However, as part of a separate action, EPA proposed new regulatory requirements on September 30, 2009 that would establish thresholds for when Clean Air Act permits under the New Source Review and Title V operating permits programs would be required. For a copy of the proposed rule and additional information on this action, please see http://www.epa.gov/nsr or contact Mr. Joseph Mangino, Air Quality Policy Division, Office of Air Quality Planning and Standards (C504-03), Environmental Protection Agency, Research Triangle Park, NC 27711 (telephone number: (919) 541-9778; e-mail address: mangino.joseph@epa.gov).