Is the approach in the proposed rule legal?
No. The Clean Air Act requires EPA to base MACT floor standards on emissions control that has been achieved in practice. It also requires EPA to set achievable standards. The proposed standards do not meet either requirement. The rule requires every U.S. facility to implement very costly control strategies to achieve compliance simultaneously with four excessively stringent standards that have not been demonstrated to be simultaneously achievable in practice and that do not take into account important factors impacting achievable emissions control by facilities, such as the composition of their nontechnological raw material inputs. Impacts on the Cement Industry Q: What is the portland cement industry? The cement industry is, quite literally, the key building block of the nation’s construction industry. Virtually no new construction activity can be undertaken without the use of concrete, and p ortland cement is in the key ingredient in concrete. Portland cement is calcium silicate ceme
