17 Section 163(a) of the CAA stipulates that increments based on averaging periods other than an

18 annual period the “maximum allowable increase” can “be exceeded during one such period per

19 year.” Consequently, compliance with the 24-hour PM2.5 increments is based on comparison of

20 the highest, second-highest 24-hour concentration increase over the entire receptor network for

19 Section 169(4) of the CAA defines “baseline concentration” as “the ambient concentration levels which exist at

the time of the first application for a permit in an area subject to this part, based on air quality data available in the

Environmental Protection Agency or a State air pollution control agency and on such monitoring data as the permit

applicant is required to submit.”

each year modeled for the 24-hour increment. Similarly, the highest 1 annual concentration over

2 the entire receptor network for each year modeled is used for compliance with the annual

3 increment.

4 The PM2.5 increment analysis includes many of the same elements discussed above for

5 PM2.5 NAAQS analyses, with some important differences. The main difference is that the

6 increment compliance demonstration is based on calculating the increase in ambient PM2.5

7 concentrations over the applicable baseline concentration, which results from proposed

8 emissions increases from the new or modified source, in combination with increment-consuming

9 emissions from other sources within the baseline area impacted by the proposed source. Another

10 key difference is that the increment analysis is based on the net impact of actual emission

11 increases and decreases from increment-affecting sources, whereas NAAQS analyses are

12 generally based on the maximum allowable emissions from all nearby sources. However, it

13 should be noted that the statutory definition of “actual emissions” in Sections 52.21(b)(21) and


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