Attached are comments of the Environmental Technology Council, the trade association for the hazardous waste management industry.
Removal of Title V Emergency Affirmative Defense Provisions from State Operating Permit Programs and Federal Operating Permit Program
Activity
Environmental Technology Council filed 2 comments on this docket between Aug 22, 2016 and May 23, 2022. 21 other organizations filed here. The comment window closed 1534d ago.
What Environmental Technology Council filed (2)
Attached are the comments of the Environmental Technology Council (ETC), the trade association for the commercial hazardous waste management industry.
Abstract
This proposed rule would remove the “emergency" affirmative defense provisions from both sets of Title V operating permit program regulations, located at 40 CFR 70.6(g) (State Operating Permit Programs) and 40 CFR 71.6(g) (Federal Operating Permit Programs). These regulations currently authorize an affirmative defense to enforcement actions brought for noncompliance with technology-based emission limitations in title V permits for exceedances that are caused by an "emergency."
View on regulations.gov →Co-filers (21)
See everyone who commented →- Environmental Technology CouncilTHIS ORG2 filings · confidence 97%
- American Coatings Associationtrade assoc.1 filing · confidence 97%
- American Foundry Societytrade assoc.1 filing · confidence 85%
- American Lung Associationtrade assoc.1 filing · confidence 85%
- and The Ohio Manufacturers' Associationtrade assoc.1 filing · confidence 85%
- Coalition for Responsible Waste Incinerationtrade assoc.1 filing · confidence 85%
- Edison Electric Institutetrade assoc.1 filing · confidence 97%
- Flexible Packaging Associationtrade assoc.1 filing · confidence 85%
- GPA Midstream Associationtrade assoc.1 filing · confidence 97%
- Healthcare Waste Institute (HWI) of the National Waste & Recycling Associationtrade assoc.1 filing · confidence 85%
- International Liquid Terminals Associationtrade assoc.1 filing · confidence 85%
- Kean Miller LLP on behalf of the Louisiana Chemical Association (LCA) and Louisiana Mid-continent Oil and Gas Associationtrade assoc.1 filing · confidence 85%
- National Association of Clean Air Agenciestrade assoc.1 filing · confidence 85%
- National Environmental Development Association's Clean Air Project (NEDA/CAP)trade assoc.1 filing · confidence 85%
- National Mining Associationtrade assoc.1 filing · confidence 97%
- P.L.C. on behalf of Nucor Corporationunverified attribution1 filing · confidence 70%
- PLLC on behalf of National Environmental Development Association’s Clean Air Project (NEDA/CAP)trade assoc.1 filing · confidence 85%
- Southern Companyunverified attribution1 filing · confidence 70%
- Southern Ute Indian Tribe Counciltrade assoc.1 filing · confidence 85%
- SSM Coalitiontrade assoc.1 filing · confidence 85%
- The Aluminum Associationtrade assoc.1 filing · confidence 85%
- Vinyl Institutetrade assoc.1 filing · confidence 85%