ENV-14-11 Gone Are The Days of the SSM Exemption

Description:

As this Paper will discuss, recent court decisions threaten to do away with EPA’s long-established policy on SSM excess emissions. This Paper will provide a look-back at the Agency’s articulation of its SSM policy, a review of the most recent (and most impactful) judicial decisions on the fate of the SSM exemption, and a discussion of how EPA is proposing to address the SSM exemption in two specific rulemaking actions affecting the refining community.