Married Under the Clean Air Act - the Single Source Determination and Problems Arising Therefrom

摘要

This paper illustrates and discusses situations where two or more independent entities are considered a single source for purposes of complying with construction (New Source Review) and operating (Title V) permit aspects of the Clean Air Act (CAA). The objective of this presentation is to inform environmental professionals of the complexities that arise from business partnerships that, under many circumstances, become complex and tenuous if one is not prepared to address them. This paper provides a background on single source determinations made by U.S. EPA and state agencies, outlining the characteristics that are factored into the single source determination (e.g., proximity, level of dedication of each business to another, etc.)