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U.S. EPA Issues Final Rule Enforcing 2015 Ban on State Exemptions for Startup, Shutdown and Malfunction Emissions

Vorys Energy

JANUARY 20, 2022

EPA’s policy on State regulatory exemptions for air emissions during periods of facility startup, shutdown and malfunction (SSM). EPA no later than November 22, 2016. This post provides an important Ohio-specific update to our October 11, 2021 post regarding U.S. Following U.S.

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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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Shutdown IT Maintenance E&A

U.S. EPA Issues Final Rule Enforcing 2015 Ban on State Exemptions for Startup, Shutdown and Malfunction Emissions

EPA’s Shifting Guidance on Startup, Shutdown, and Malfunction Defenses in State Implementation Plans and Its Effect in Louisiana

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