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

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

  1. Yes…what wonderful ideas!…but none of them dare to mention the use of oxygen, production of carbons, phenols, poisons, spreading of dust and disease, through the relentless invasions sending debris around the world and into rivers oceans and areas where they can mutate perhaps under more favorable conditions than whence they originated. Cowardice…fear of being ‘over enthusiastic’ instead adopting misplaced ‘loyalty’ is a reasonable conclusion….the reason a lot of hot air is blown to no useful outcome. By the way in all the pollution debate escalating overpopulation and the amount of air available I have never seem examined….

    How many billions of people crammed jammed unemployed and frustrated the planet support even to breathe, let alone die from respiration and spittle-transmitted disease.

    The present so called ‘refugee migration’ drowning host nations in massive debt, will ensure rapid overpopulation along with pollution of resources as they reproduce to empower their religious fixations, as Catholics (I’m one) were ‘obligated to do’ in earlier centuries slaughtering millions to get rid of the competition.

    The world is vastly more populated now and for billions I think it reasonable to say, sex is their only ‘release’ and ‘pleasure’ .

    To survive we must act to survive without war. I recognise the academic aspects of the people illustrated but I see no statement of what use they will be to us, the people not the EPA….Smoke and Mirrors are the mindset of politicians today, and as can be seen by any administration and Trump is a fair example, we are just the serfs paying taxes for the lifestyle of the new order.

    All this IS relevant to air-pollution, the spread of disease and progressive extermination of our marine life and increase in air temperature in which air conditioning has effect.

    Setting aside the military and financial support of evil governments. e.g. Israel has received more than $300B from US and also banned weapons whilst ignoring Israeli industrial espionage in US military and Health assets for example.

    Israel then produces and sells devices in competition to its ‘allies’ from whom the espionage is forever perpetrated.. and we are the ants and bees who provide the nourishment of such evils as the Bilderbergers. Israel produced and sold defective, (perhaps Israeli controllable) ‘early warning devices’ to Syria for example.

    It could not have been anything but well known and intended that without Hussein being ‘taken out’ IS would flounder. Based on lies Iraq was twice massively invaded…What was the outcome…vast airborne pollution and terrorism and the removing from Israel the threat of a modern well founded Arab state offering greater equality to women. Then commenced the spreading militarism, the blowing to lumps and dust of the infrastructure rest of the pawns….polluting the planet, which is an avoided subject.

    The new world order is well advanced and so is its the march to war, which can exterminate billions of people. Perhaps it is getting out of control…they have not yet prepared another planet…We must I say look at clean air as our best friend, along with earth and water and refuse to allow Governments to beat their hairy chests at each other and accelerate the demise of the people who simply want to live in quiet enjoyment.

  2. A resume is not a solution, not even a start to a solution of air pollution. Commitment, expertise, real solutions, courage to stand firmly against pathological government and industry and and empowerment are a start. None of the academics depicted in the article has indicated any will to undertake the mission for clean . This not a video game one can start over and over , it’s a war. We have to want to survive and get rid of governments and ‘leaders’ who will not act to prevent air pollution introduced by any cause whatsoever….In closing also never mentioned by media as far as I can see is that it takes 50 years for the effects of ‘greenhouse’ gases, and there are worse than carbon variants, to peak…so for example we are still experiencing the effects of WW11, Korea (which acted to produce an atomic bomb owing to Macarthur’s crazed demands US drop an atomic bomb on Nth Korea and Vietnam. Macarthur had the US air-force straff the long lines of refugees….another obscenity. Our children and grandchildren will suffer as well the effects from Iraq, Afghanistan, Palestine and Syria….far more than we do. To quote Lee Marvin, dying in Raintree County “Another glorious victory”.

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