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Mack McGuffey practices environmental law as an associate in Troutman Sanders' Atlanta office and specializes in regulatory compliance under the Clean Air Act. Last November at the last webinar on the IBMACT before the rule was published, he gave a very good presentation on the status of the ruling and potential future litigation. Now that the rule is out, Mack was able to provide an overview of the MACT program, explain how EPA's final Industrial Boiler MACT standards differ from the ones it originally proposed, and describe some of the legal issues associated with EPA's final rule. A key point made was that although EPA indicated that because of concerns over the legality of the significant changes between proposed rule and final rule, EPA is taking comment on the final rule, any delay in or stay of the deadline for compliance is very unlikely. He also emphasized that affected boiler operators must do whatever is necessary to comply with the new emission limits. Just installing additional control equipment will not be sufficient.
Revision Date: 3/10/2011
Tags: 221112 - Fossil Fuel 化石燃料, Troutman Sanders, Consulting, MACT
Carroll "Mack" W. McGuffey III, Associate at Troutman Sanders LLP, told the participants that it is unlikely that the final rule will be delayed by lawsuits. The litigants can petition to stay the rule until the litigation is complete but the D.C. Circuit Court is unlikely to do so. So the clock will be ticking and compliance will be required in 2014. The lawsuits can focus on several issues. One is the lack of five or more sources achieving the limits on any one pollutant. Another is the argument that a source which achieves the limit on one pollutant but not another is not a valid example.
Revision Date: 11/18/2010
Tags: 221112 - Fossil Fuel 化石燃料, Troutman Sanders, MACT