The changing U.S. regulatory landscape for alternative fuels

The use of alternate fuels and raw materials in the cement manufacturing process has evolved substantially over the last two to three decades, along with approaches to acquire regulatory approval. Most recently, EPA has published new regulations as an overlay to what has been in place, having the potential to significantly impact this practice. Instead of dealing with the state agencies that usually have permitting authority; the new rules add another layer of regulatory hurdles by EPA. The new regulations also force a more significant overlap of the air permitting and solid waste rules. As a result, implementing an alternate material program and seeking approval has the potential to be considerably more challenging for the regulated community, in addition to adding complexity for state agency permitting staff. This paper provides an update on the latest solid waste and air regulations applicable to alternative material use in cement plants, and potential implications for the U.S. industry. Early experiences will be explored, in addition to contemplating potential permitting and/or approval pathways expected to be encountered with the newest regulations in place.