As we previously reported, in May 2015 US EPA issued a direct final rule allowing for the rescission of certain preconstruction (“PSD”) permits issued by US EPA and delegating permit review authority to states under Step 2 of the Greenhouse Gas (“GHG”) Tailoring Rule.  Step 2 of the Tailoring Rule set in motion PSD permitting for “GHG-only” sources, meaning sources permitted solely … Continue Reading