A Plant-wide Applicability Limit (PAL) is an annual emission
limitation that allows facilities to be modified, changed or
altered without first obtaining a New Source Review permit. A PAL
permit eliminates the need for companies to create separate
emissions caps and permitting processes for each piece of equipment
or components within a plant. They are extremely valuable to
manufacturing companies investing in new projects, machinery and
plants, and those experiencing frequent delays in the traditional
project permitting process.
Foley & Lardner LLP helped Bemis Company, Inc., a global
manufacturer of flexible and rigid plastic packaging products,
secure a PAL permit for their facilities in Wisconsin – the
first in the state. Although PAL rules are already "on the
books" in most states, not many companies are taking advantage
of PAL permitting ... possibly due to continued-after effects of
the recession and a period where facility expansions were not
common.
