NSPS Subpart OOOO Lessons Learned … and a Look Ahead

摘要

1. Subpart W 2. EPA issued rule relatively quickly 3. Series of legal challenges 4. Numerous rule updates 5. Despite best efforts, there are always more compliance details to chase down or confirm 6. Subpart OOOO 7. All of the above 8. Plus... 9. Some compliance deadline deferrals, but No BAMM 10. Even higher bar for ongoing demonstration of compliance for affected sources under the rule.