EPA’s Shifting Guidance on Startup, Shutdown, and Malfunction Defenses in State Implementation Plans and Its Effect in Louisiana
The Energy Law
OCTOBER 14, 2021
On September 30, 2021, the EPA once again signaled a policy change on what provisions a state can include in its Clean Air Act State Implementation Plan (“SIP”) for exemptions and affirmative defenses during periods of startup, shutdown, and malfunction (“SSM”). 33840 (June 12, 2015). at 33967-68.
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