Tuesday, September 27, 2011

Our EPA is Growing to Meet the Needs of a Growing... EPA

NOTE TO LIBERALS:  The above graphic is a JOKE.  Please continue
to breathe normally throughout the remainder of this post.  Thank you!
Found on the Daily Caller:  EPA: Regulations would require 230,000 new employees, $21 billion

In yet another breathtaking example of how THIS President is 'Creating / Saving Jobs' the Environmental Protection Agency needs to add workers to enforce new policies and procedures which it believes are "absurd and impossible to administer (by 2016)". 

Aw, come on, who would say something that LOONEY.  It was some wack-job Republican Presidential Candidate, wasn't it?!?!

Um, No.  The EPA said it...

Come on Cow Guy, you LUNATIC - back THAT up!

Okay (Page 83 of 161)...  (Never doubt the guys in the MoosRoom)

While EPA acknowledges that come 2016, the administrative burdens may still be so great that compliance at the 100/250 tpy level may still be absurd or impossible to administer at that time, that does not mean that the Agency is not moving toward the statutory thresholds.  

[MoosNote:  Yes, the EPA will move forward with the task, whether it is obtainable, or not.]
To the contrary, through this regulatory process "EPA intends to require full compliance with the CAA applicability provisions of the PSD and Title V programs...."


Also found in the same document, the 09/16/2011 EPA court filing, Page 49 (of 161) states:  
When EPA assumed a mere 40-fold increase in applications – one-tenth of the actual increase – and no increase in employees to process them, the processing time for Title V permits would jump from 6-10 months to ten years.

Hiring the 230,000 full-time employees necessary to produce the 1.4 billion work hours required to address the actual increase in permitting functions would result in an increase in Title V administration costs of $21 billion per year.
Id. at 31,535-40, 31,577.


Yes, EPA is expanding to meet the needs of an expanding EPA. 

AND, just to make it interesting, they believe their task isn't even 'possible' due to the dramatic increased scope of increased governmental-mandated 'Green House' gas legislation. 

How weird could it be?  Thanks for asking!

Check out the following section from Page 16 of the above document which discusses Title V required reporting:

Title V of the CAA, enacted in 1990, establishes an operating permit program covering stationary sources of air pollutants. 42 U.S.C. §§7661-7661f. Similar to PSD, the Title V operating permit requirement applies to, among others, any “major source” within the meaning of 42 U.S.C. §7661(2), including stationary sources that have the potential to emit 100 tpy of “any air pollutant.” 42 U.S.C. §7602(j). Like PSD, EPA has long interpreted this requirement to apply to any air pollutant that is actually subject to regulation under the Act.  75 Fed. Reg. at 31,553-54.


Title V does not impose substantive pollution control requirements of its own. Instead, Title V requires that each source have a comprehensive operating permit to ensure compliance with all emissions limits and requirements applicable through other provisions of the CAA. 42 U.S.C. §7661c(a). Each State’s Title V program must contain procedures for expeditiously processing permit applications. 42 U.S.C. §§7661a(b)(6), 7661b(c). 

[MoosNote:  Italics added to emphasize the salient points...]


Okay so here's the deal:  If you 'build / create / or implement something' (anything) which might produce 'emissions' you'll need to get a permit processed through EPA.  This permit will not require that the 'something' generate 'low' emissions, but rather, your business (residence?) will need to obtain a 'comprehensive operating permit' stating that yes, you are stinking up the place.

In short, if you plan on 'something' you'll need to go through the newly 'Improved' EPA Title V permitting process.  This is why EPA needs to HIRE almost a quarter of a million new government workers - to permit your 'something' (whatever your 'something' happens to be.)

Here's MY question for you:  If I'm understanding the above correctly, this permitting merely tracks the fact that you have documented your 'something', right? 

The next logical question is this:  Once your 'something' is documented under Title V, won't the Feds need additional EPA folks to go out and then 'monitor' your 'something' to make sure that you fall within your initial specifications turned in via permit to the nice folks at EPA?  What's the use of having a permit, if the thing 'permitted' is not measured?

Folks, we're not talking about an additional quarter of a million new Federal workers here, we're talking about a much larger number of workers.  Figure a quarter-million paper-pushers and probably twice that number on the street walking around with futuristic Star Trek Tricorders in their out-stretched hands. 
I'm from the Government.  I'm here to help.
(Not an actual government employee)

But I guess we'll find out about this later this year, or next, once the initial 230,000 clerks are put on the Federal 'books'. 

Cost?  A meager $21 BILLION per year (forever.)

Sheesh, I must be getting old.  I remember when $21 BILLION used to seem like a lot of money. 

Oh, before I forget (and prior to some Liberal genius decides to send it to me) MediaMatters has already said that the report in the DailyCaller is false, in fact the EPA 'fixed' the situation back in May of 2010 via the use of a 'Tailoring Rule'. 

Okay, let me ask you this, if this situation was 'fixed' in 2010, why was the EPA report cited above filed in court on September 16, 2011?

Inquiring minds want to know.

Yeah, and I want to know too...
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