What changes can be made to the proposed rule to reduce its negative impacts on the U.S. cement industry?
This rule should be re-worked to take into account more real world data and more realistic assumptions about the cement industry and about what controls can be placed on cement kilns and the emissions reductions such controls can achieve in practice. The EPA should reject the pollutant-by-pollutant approach and set MACT floors based upon requirements that are demonstrably achievable and that take regional and other kinds of relevant variability into account. And, as suggested in the recent Brick MACT decision, EPA should establish appropriate subcategories of the regulated community in order to ensure that standards are both achievable and reasonable.
Related Questions
- Are there any proposed changes to the minimum number of letters needed to fill a tray (150-piece rule) for either rate eligibility or mail preparation purposes?
- What changes can be made to the proposed rule to reduce its negative impacts on the U.S. cement industry?
- How will the proposed rule affect the U.S. portland cement industry?
