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Let the People Speak: Notice-and-Comment Rulemaking (Lessons From the Controversial New Source Review Proposal of the Clean Air Act)

Sections 165 and 173 of the CAA specifically note that any change in pollution levels from an existing source triggers NSR and accompanying technological upgrades. Nothing in the rulemaking's proposed definition based on cost of changes...

A Tale of Two Theories: The Legal Basis for EPA's Proposed Revision to the Routine Maintenance, Repair, and Replacement Exception, and the Implications for Administrative Law

How many lawyers, regulators, engineers, and contractors does it take to change a light bulb? Lots, if you happen to be changing the light bulb at a "stationary source" of pollution, and the bulb change counts as a "modification" of the...

The Proposed WEPCo Rule: Making the Problem Fit the Solution

Editors' Summary: EPA's final decision on its proposed WEPCo rule, which addresses how new Clean Air Act provisions apply to electric utilities, is expected soon. This Article provides a glimpse into the regulatory machinery needed...