On Friday, the D.C. Circuit reinstated the affirmative defense for emergency situations resulting in exceedances of emission limitations in Clean Air Act Title V operating permits. That defense, available in the Title V...more
The National Association of Clean Air Agencies (“NACAA”) submitted April 10th comments to the United States Environmental Protection Agency (“EPA”) addressing a rule proposed on January 9th titled: Clarifying the Scope...more
Major sources of air pollution must obtain a Clean Air Act Title V permit under their state’s EPA- approved implementation plan. Permits, of course, can be challenged. By petition to the EPA Administrator, the Sierra Club...more
A 2015 EPA rulemaking required 36 states to revise their State Implementation Plans (“SIPs”) to eliminate provisions exempting air emission exceedances during periods of startup, shutdown, or malfunction (the “SSM SIP Call...more