EPA's SIP Call on Startup, Shutdown, and Malfunction Air Emissions: Practical Implications

摘要

On June 12, 2015, the United States Environmental Protection Agency ("EPA") issued a call for state implementation plan ("SIP") revisions to revise affirmative defenses and exemptions for emissions during startup, shutdown, and malfunction ("SSM") periods. Reflecting a change in policy, EPA found that SSM-related SIP provisions in 36 states were "substantially inadequate" to meet Clean Air Act ("CAA") requirements. EPA's SIP call allows affected states until November 22, 2016, to submit SIP revisions.