Barnes & Thornburg Alert - June 2015 - EPA Eliminates Another Source of Startup, Shutdown and Malfunction Exemptions from Clean Air Act

EPA finalizes demand for 36 states to remove automatic SSM exemptions from SIPs, no later than Nov. 22, 2016.

Neither EPA nor the states may provide facilities with an affirmative defense for Clean Air Act violations that would alter the jurisdiction of the federal courts to assess civil penalties.

Agencies may still exercise enforcement discretion on case-by-case basis and consider state interpretive letters when assessing State Implementation Plans for compliance with new startup, shutdown and malfunction requirements.

Please click here for the full alert.

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