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Environmental Policies › Affirmative Defenses

Clark Hill PLC

EPA Proposes Eliminating State Regulations as to Startup, Shutdown, and Malfunction Emissions

Clark Hill PLC on

Operating conditions during periods of startup, shutdown, and malfunction (SSM) are not normal and often result in unrepresentative emissions that exceed permitted limitations. Originally published in The Natural Gas &...more

Foley Hoag LLP - Environmental Law

EPA Proposes to Eliminate Affirmative Defenses for Excess Emissions During Startups, Shutdowns, or Malfunctions — Get Ready for...

Foley Hoag LLP - Environmental Law on

This past April, the D.C. Circuit struck down the part of EPA’s cement kiln rule that would have provided an affirmative defense to civil penalties for excess emissions resulting from unavoidable malfunctions. As we noted at...more

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