Control Technique Guidelines

Summary

Control Techniques Guidelines (CTGs) are documents issued by the U.S. Environmental Protection Agency (EPA) to provide States with the EPA's recommendation on how to control the emissions of volatile organic compounds (VOC) from a specific type of product or source category in an ozone nonattainment area. The Clean Air Act (CAA) provides that the EPA may issue CTGs in place of National regulations when the EPA determines that a CTG will be substantially as effective as a regulation in reducing VOC emissions from the product or source category in ozone nonattainment areas. The chart below is a list of CTGs that the EPA has issued from 1994 through 2008. The information provided under the category "Group II CTGs issued 9/29/06" for the flexible package printing and lithographic and letterpress printing CTGs also includes certain documents, identified with an asterisk "*", that were used as background material in the development of these CTGs.

A State with ozone nonattainment areas is required to evaluate the recommendations provided in the CTGs and determine if it must modify existing regulations or create new regulations to be consistent with the requirements of the CTG. A State that is included in the Ozone Transport Region (OTR), like Pennsylvania, must apply the requirements statewide for all sources covered by the CTG. After a State promulgates a regulation implementing the requirements of the CTG for a product or source category, the State must submit the regulation to the EPA for approval as part of the State's implementation plan.

Background

Section 183(e) of the Clean Air Act (CAA) directs the U.S. Environmental Protection Agency (EPA) to list for regulation those categories of products that account for at least 80% of the volatile organic compound (VOC) emissions from consumer and commercial products in ozone nonattainment areas. 42 U.S.C.A. 7511b(e). Section 183(e)(3)(A) of the CAA directs the EPA to divide the list of categories into 4 groups, establishing priority for regulation based on certain criteria. 42 U.S.C. 7511b(e)(3)(A).

Section 183(e)(3)(C) of the CAA further provides that the EPA may issue a Control Techniques Guidelines (CTG) document in place of a National regulation for a product category where the EPA determines that the CTG will be "substantially effective as regulations" in reducing emissions of VOC in ozone nonattainment areas. 42 U.S.C.A. 7511b(e)(3)(C). The CTG provides states with the EPA's recommendation of what constitutes reasonably available control technology (RACT) for the covered category.

Section 172(c)(1) of the CAA provides that State Implementation Plans (SIP) for nonattainment areas must include reasonably available control measures, including RACT, for sources of emissions. 42 U.S.C.A. 7502(c)(1). Section 182(b)(2)(A) of the CAA provides that for moderate ozone nonattainment areas, a state must revise its SIP to include RACT for each category of VOC products or sources covered by a CTG document issued between November 15, 1990, and the date of attainment. 42 U.S.C.A. 7511a(b)(2)(A). Section 184(b)(1)(B) requires statewide implementation in Pennsylvania of RACT for all sources covered by a CTG by virtue of Pennsylvania's inclusion in the Ozone Transport Region (OTR). 42 U.S.C.A. 7511c(b)(1)(B).

Each CTG includes a "presumptive norm'' or "presumptive RACT'' that the EPA believes satisfies the definition of RACT. If a state submits a RACT rule that is consistent with the presumptive RACT, the state does not need to submit additional support to demonstrate that the rule meets the CAA's RACT requirement. However, if the state determines to submit an alternative emission limit or level of control for a source or source category for which there is a presumptive RACT, the state must submit independent documentation as to why the rule meets the statutory RACT requirement. (62 FR 44674, August 22, 1997)