When Maybe Is Good Enough: The Title V Citizen Petition

摘要

EPA appears to be using the Title V objection and veto authority to force states to address, in a substantive manner, the allegations made by third-party petitioners about the deficiencies of proposed Title V permits. While EPA's own rules only require the state to record the names of commenters and their issues to allow EPA to "fulfill his obligations under [the CAA] . . . .," EPA is now deferring its ultimate responsibility to the states.