Air Permitting: Sixth Circuit Vacates Single Stationary Source Aggregation Determination for E&P Facilities Due to EPA’s Unreasonable Interpretation of Adjacent
The Energy Law
AUGUST 16, 2012
. §§ 51.166(b)(6); 71.2. The question of what is “contiguous or adjacent” has long been vexing for the exploration and production industry. Under different administrations, EPA has changed its guidance on the meaning of this phrase. Two years later, EPA withdrew that guidance, reemphasizing the criteria set out in the regulations. 09-4348, slip op.
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