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Would the APCD require a source with pre-rule-adoption NEI greater than the threshold to offset its NEI even when it applies for an emission decrease?

April 26, 2017apcd applies emission greater nei offset require source threshold

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Would the APCD require a source with pre-rule-adoption NEI greater than the threshold to offset its NEI even when it applies for an emission decrease?

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With the new lower offset trigger there may be sources that already have pre-existing NEI’s greater than the threshold that have never been mitigated through offsets. Any source in this situation will be required to offset the entire NEI at their next modification. However, sources are not required to offset their NEI if they apply for a modification that results in a decrease in emissions.