webinar will provide historical context for EPA’s rulemaking, the potential for
EPA enforcement and citizen suits that EPA’s SIP actions may present in the
future, and the mechanics of state rulemakings and EPA procedures for reviewing
and approval of SIP revisions. The speaker will discuss the potential effect of
the SIP call and SSM rule revisions on startup and shutdown procedures, best
practices during these events to minimize emissions and how “affirmative
defenses” operate. The likely effect of these regulatory developments on
Title V permit and MATS compliance and whether it is possible to coordinate
provisions to provide operating certainty will also be discussed.
webinar is the first in a series of two webinars. The second webinar will
examine options states are considering in rulemaking, potential permit revisions
involving SSMs and best management practices, the best types of affirmative
defenses, utility best practices, and other issues. It is not necessary to
participate in both webinars, but it may be beneficial.
The Ritts Group, Outside Counsel to APPA