MANY FACILITIES PROPOSING MODIFICATIONS SINCE THE PASSAGE OF THE CLEAN AIR ACT AMENDMENT OF 1990 HAVE EVALUATED THE ADDITIONAL IMPACT OF TITLE III ON THEIR PLANS. THIS ANALYSIS ALLOWS THE COMPARISON OF BACT OR LAER REQUIREMENTS WITH THOSE OF THE TITLE III MAXIMUM ACHIEVABLE CONTROL TECHNOLOGYH (MACT). A CASE STUDY IS PRESENTED FOR A HEAVY TRUCK MANUFACTURER PLANNING A FACILITY EXPANSION FOR PAINTING TRUCKS USING WATERBORNE MATERIALS TO REDUCE EMISSIONS AT THE PROCESS RATHER THAN ABATEMENT AT THE STACK.