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Sierra Club Affirmative Defenses

Williams Mullen

EPA Issues SIP Call to Eliminate SSM Defense

Williams Mullen on

EPA has issued a final rule that requires 36 states to revise their State Implementation Plans to eliminate a well-known and often-used Clean Air Act defense for excess emissions. While specific elements of the defense...more

Blank Rome LLP

Nothing but Nonsense in New EPA Rule on Emissions

Blank Rome LLP on

In response to a petition for final rule-making filed by the Sierra Club, the U.S. Environmental Protection Agency issued on May 22, 2015, its final action requiring 36 states to revise their state implementation plans...more

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

McDermott Will & Emery

EPA Proposes to Eliminate Affirmative Defenses for Many Clean Air Act Violations

McDermott Will & Emery on

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on September 5, 2014 that would prevent states from including affirmative defenses in their Clean Air Act state implementation plans (SIPs) for emissions...more

BakerHostetler

Sierra Club Seeks to Vacate Affirmative Defenses under Clean Air Act for Unavoidable Malfunctions

BakerHostetler on

This month, the Sierra Club filed a petition for review challenging certain provisions of nine EPA rules that provide for affirmative defenses against alleged Clean Air Act violations in the case of unavoidable malfunctions....more

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