agreement with the U.S. EPA.' The PSD permit program is an element of the Clean Air Act ("CAA”) that requires preconstruction review and approval for new and modified major stationary sources. CAA § 165, 42 U.S.C. § 7475. As outlined in our previous decision regarding the planned Knauf facility, the PSD review process involves several technical analyses and determinations as well as specific procedural requirements designed to implement the CAA's emphasis on public participation and input. Knauf I, 8 E.A.D. at 123-24. The PSD review process for the proposed Knauf facility officially began in March 1997, when Knauf first submitted a PSD permit application to SCAQMD. The proposed facility is subject to PSD review due to its anticipated emissions of particulate matter less than 10 micrometers in diameter ("PM10"). During the course of the original review process, SCAQMD conducted analyses of best available control technology ("BACT") and air quality impacts relating to PM10. In addition, SCAQMD solicited comment on the terms of a draft permit for the proposed facility and held a public hearing. See Knauf I, 8 E.A.D. at 125 (providing details of SCAQMD's administrative review of the Knauf permit application in 1997-1998). After issuing a final permit decision in March 1998, several individuals and entities filed petitions for review with the Board, seeking our review of SCAQMD's permit decision and elements of its review process. Knauf I examined several aspects of SCAQMD's original PSD review process. We denied review of all of the issues raised in the appeal with the exception of two items for which we felt that SCAQMD's decisions were not adequately justified on the record. Knauf I, 8 E.A.D. at 174-75. The two items that warranted a grant of review were: (1) the PM10 BACT determination, and (2) conclusions regarding environmental justice. Id. The Board remanded the PSD permit to SCAQMD to provide supplemental analyses of these items and to make the analyses available for public comment. Id. The Board specifically limited the scope of the remand to these two issues. Although the Board expressly allowed for appeals upon conclusion of the remand procedures, we also cautioned that "[t]he subject matter of any such appeal must be limited to the issues identified in the remand order." Id. at 73. 1 U.S. EPA delegated authority to the SCAQMD to administer the federal PSD program in 1985. The permits that SCAQMD issues pursuant to that delegation are considered federal permits subject to federal permitting procedures, including the potential for review by the Environmental Appeals Board under 40 C.F.R. § 124.19. See In re RockGen Energy Center, 8 E.A.D. 536, 537 n.1 (EAB 1999); Knauf I, 8 E.A.D. at 123; 40 C.F.R. § 124.41 ("when EPA has delegated authority to administer [permitting] regulations to another agency ***, the term EPA shall mean the delegate agency and the term Regional Administrator shall mean the chief administrative officer of the delegate agency.") 2 PSD review is triggered for PM10 if a source has the potential to emit 15 tons per year or more of PM10 emissions. 40 C.F.R. § 52.21(b)(23)(i). The annual PM10 emissions from the proposed Knauf facility are well above this threshold. During the remand period, SCAQMD prepared and/or obtained the supplemental analyses required by the Board's order. SCAQMD also prepared a revised draft permit, and made the revised permit, along with the supplemental analyses, available for public comment in April 1999. On June 2, 1999, SCAQMD held a public hearing on the revised permit. SCAQMD issued a final revised permit along with two response to comments documents on August 17, 1999. See Federal Prevention of Significant Deterioration (PSD) Authority to Construct (Aug. 17, 1999) (“Revised Permit"); Response to Comments, Written Comments Submitted During Public Comment Period ("Resp. to Comments"); Response to Comments, Public Hearing 6/2/99 (“Public Hear. Resp."). During September 1999, the Board received sixty-five (65) petitions for review regarding the revised permit for the proposed Knauf facility.3 Sixty-four (64) of these petitions were filed by citizens or citizens' groups who oppose the Knauf facility. One petition was filed by another fiberglass manufacturer, CertainTeed Corporation. Most of the citizen petitions request that the Board deny the permit issued to Knauf. At the Board's request, SCAQMD prepared responses to each of the petitions for review. Petitioners were subsequently granted the opportunity to file replies to the SCAQMD responses. Notice to All Petitioners and Order Granting Motions for Leave to File Reply Briefs (Nov. 16, 1999). EPA Region IX, which was a petitioner in Knauf I, but did not file a petition for review of the revised permit decision, sought permission to file an amicus brief in this proceeding. The Board granted that request. Order Granting Motion for Leave to File Amicus 3 The petitioners (and corresponding appeal numbers) are: Robert Rollins (99-8), Colleen Leavitt (99-9), Mary Scott (99-10), David Nigro & Paula Hetzler (99-11), Debra Kaut (99-12), Betty Doty (99-13), Dorothy Kearsley (99-14), Walter May (99-15), Citizens for Cleaner Air et al. (99-16), Arnold Erickson (99-17), Russ Wade (99-18), Earl Hastings (99-19), Doreen Hastings (99-20), Ivan Hall (99-21), Barbara Frisbie (99-22), Stuart Oliver (99-23), Stuart Oliver & Jonathan McInteer (9924), Radley Davis (99-25), Judy Sills (99-26), James Sills (99-27), April Frank (99-28), Warren Teel (99-29), Sharon Bellomo (99-30), Dwight Bailey (99-31), William Caraway (99-32), Vicki Caraway (99-33), Dara Caraway (99-34), Joanna Caul & Richard Sanford (99-35), Robert DiGiulio (99-36), Robert & Constance Hegge (99-37), Heidi Silva (99-38), Suzanne Auteni-Tony (99-39), Rhonda Posey (99-40), Gloria Zeller (99-41), Jim Price (99-42), Judy Hansen (99-43), Barbara Condon (9944), Elizabeth Ballou (99-45), Joseph & Lillian Hernandez (99-46), Bonnie Rule (99-47), Cindy Christie (99-48), Aracelia Briggs (99-49), Rebecca Christie (99-50), Becky Wilson (99-51), Ron Pearsall (99-52), George McArthur (99-53), Georgette McArthur (99-54), James Melby (99-55), Carolyn Singelmann (99-56), Fulton Doty (99-57), Nadine Stutsman (99-58), Patricia Cogburn (99-59), Bryan Jones (99-60), Orville & Juanita Vanderzanden (99-61), Doreen Melby (99-62), Linda Andrews (9963), Jeffrey Lewellyn (99-64), Barbara Jo Garner (99-65), CertainTeed Corp. (99-66), Justin Jones (99-67), Hans Ortlieb (99-68), Tillie Smith (99-69), Laurie O'Connell & Ed Barger (99-70), Joy Newcom (99-71), Fulton Doty (99-72). Specific petitions are cited herein as "Petition [#]." 4 SCAQMD's responses are cited herein as "Resp. to Petition [#]." We refer to specific pages within the response by the administrative record page number, i.e., (AR #). Brief (Nov. 10, 1999). The amicus brief represents the views of Region IX, EPA's Office of Air and Radiation, and EPA's Office of Environmental Justice. Amicus Brief of EPA Region IX, EPA Office of Air and Radiation, and EPA Office of Environmental Justice in Support of Shasta County, California, Air Quality Management District's Response to Petitioners ("EPA Amicus Brief"). Through its responses to the petitions for review, SCAQMD challenged several petitions on the threshold regulatory requirements of timeliness and standing. The Board reviewed all of the petitions for compliance with the timeliness and standing requirements and issued an order dismissing several of the petitions for review on timeliness and standing grounds. Order Dismissing Certain Appeals on Timeliness and Standing (Jan. 3, 2000).5 II. DISCUSSION A. Scope of Review 1. Preliminary Requirements In determining whether to grant review of a petition for review of a PSD permit, the Board first looks to whether the petition meets the threshold procedural requirements of the permit appeal regulations. See 40 C.F.R. § 124.19; In re Sutter Power Plant, 8 E.A.D. at 685 (EAB 1999). The threshold procedural requirements include timeliness, standing, and preservation of an issue for review. As discussed above, the Board issued an earlier order dealing with timeliness and standing." In that order, we noted that we also expect petitions for review to meet a minimum standard of specificity. See Order Dismissing Certain Appeals on Timeliness and Standing at 2 n.1 (Jan. 6, 2000); citing In re Envotech, L.P., 6 E.A.D. 260, 267 (EAB 1996). To meet the specificity requirement, petitioners must include specific information supporting their allegations. Petitions for review may not simply repeat objections made during the comment period; instead they must demonstrate why the permitting authority's response to those objections warrants review. Sutter, 8 E.A.D. at 687 (EAB 1999); In re Encogen Cogeneration Facility, 8 E.A.D. at 244, 251-52 (EAB 1999). 5 The January 3 order disposed of the following petitions for review in their entirety: 99-12, 99-25 through 99-28, 99-31, 99-39 through 99-52, 99-55, 99-56, 99-60 through 99-62, 99-64, 99-65, 99-67, 99-70. Supplemental letters in support of petition numbers 99-17 and 99-38 were also dismissed. The threshold procedural requirement that issues be properly preserved for review is not contested in this case. As we explained in Knauf I, the Board broadly construes petitions filed by persons unrepresented by legal counsel. Knauf I, 8 E.A.D. at 127. While the Board expects such petitions to meet the requirement of specificity, it does not expect those petitions to contain sophisticated legal arguments or to employ precise technical or legal terms. Id.; Sutter, 8 E.A.D. at 687. For purposes of specificity, the Board expects such petitions to clearly identify the issue being raised and to provide some supportable reason as to why review is warranted. Knauf I, 8 E.A.D. at 127; Sutter, 8 E.A.D. at 687-88. In this case, many of the petitions for review fall far short of even this generous approach to specificity. Most of the petitions do not identify even one particular permit condition as a basis for an appeal. While many of the petitions for review allude to the two issues that were the subject of the Board's remand order, i.e., BACT and environmental justice, few of them discuss why SCAQMD's written responses on these issues are incorrect or inadequate. It is clear from reading all of the petitions for review, that the petitioning citizens and citizens' groups feel strongly that the Knauf facility, at least as currently designed, is inappropriate for the Shasta Lake community. We respect the petitioners' right to voice their objections, but for us to fairly and accurately examine the merits of this appeal, we must insist that minimum specificity standards are adhered to. There are nonetheless, approximately one dozen petitions for review that satisfy the preliminary requirements, including specificity. These petitions fairly represent the overall collection of petitions for review filed by citizens and citizens' groups. Of these, certain petitions for review do a particularly good job of highlighting the issues and objections to SCAQMD's responses. For purposes of brevity and clarity, we will refer only to selected petitions in our discussion of the merits on the issues before us. We view the petitions cited herein as representative of the entire collection of citizens' petitions meeting the preliminary requirements. 2. Standard of Review for a Grant or Denial of Review in a Permit If the preliminary requirements have been satisfied, the Board will determine whether a petition for review shows that the permit decision in question was based on a clearly erroneous finding of fact or conclusion of law, or if the decision involves an important policy consideration or exercise of discretion that warrants review. 40 C.F.R. § 124.19(a); Knauf I, 8 E.A.D. at 126-27. If either of these conditions is met, the Board will grant review and potentially remand the permit decision. If neither of the conditions is met, the Board denies review of the petition. The above standard of review is applied stringently in practice, in keeping with the directive in the preamble to section 124.19 that the "power of review should be only sparingly exercised" and "most permit conditions should be finally determined at the [permitting authority] level." 45 Fed. Reg. 33,290, 33,412 (May 19, 1980). Thus, it is infrequent that the Board will grant review in a permit appeal. The Board exercises this authority only when the petitions for review and the administrative record are abundantly persuasive that the Board's active involvement in the matter is warranted. 3. Limitations on Scope of Review Established by the Remand Order In this case, the potential for a grant of review is also limited by the Knauf I decision. That decision was final as to all issues associated with the PSD permit for the proposed Knauf facility, with the exception of two: BACT and environmental justice. Those are the issues that were the subject of our remand order to SCAQMD, and are the focus of this decision. As noted above, the Knauf I decision explicitly limited any post-remand appeals to those two issues. Knauf I, 8 E.A.D. at 175-76. Therefore, we decline review of the abundance of miscellaneous issues raised in the petitions for review. Some of the issues outside the scope of review for this post-remand appeal are issues that were specifically addressed and for which review was denied in Knauf I. This category includes issues such as: concerns about federal and state air quality standards, permit limits on hazardous air pollutant emissions, the PM10 mitigation plan, the desire for an environmental impact statement under the National Environmental Policy Act, and use of local landfills for waste disposal. In addition, the petitions for review raise some new issues that were not before us in Knauf I. Such issues may not be raised at this juncture because the scope of the remand was expressly limited. All other issues pertaining to this PSD permit should have been raised at the time of the first appeal. Issues raised outside of the appeals period on the original permit are considered untimely. See Knauf 1, 8 E.A.D. at 126 n.9 (new issues raised in reply briefs are equivalent to late filed appeals and must be denied as untimely). The only exception to the limitation on the scope of review as established by the remand order is for issues pertaining to permit conditions that were modified during the remand period. Such permit conditions may qualify for review because the conditions have not been previously subject to the appeal process. In this case, an issue has been raised regarding SCAQMD's modification of the permit in light of the National Emission Standards for Hazardous Air Pollutants ("NESHAP") for the fiberglass manufacturing industry. See 64 Fed. Reg. 31,695 (June 14, 1999). The fiberglass NESHAP was promulgated in June 1999, during the remand period, and we may examine the issue raised in the petitions for review regarding the permit's consistency with this regulation. The next section of the Discussion describes the revised BACT determination reached by SCAQMD during the remand period and addresses issues raised |