In what is now clear to be a series of policy changes to ease air permitting requirements for industrial and manufacturing facilities, U.S. EPA has issued its second memorandum entitled “Project Emissions Accounting under the...more
The Final EPA Rule under the Clean Air Act (“CAA”) emissions standards for the Startup, Shutdown, and Malfunction (“SSM”) Rule is out. EPA issued the Final Rule on May 22, 2015 and it’s even worse than when proposed. I...more