Regulatory Affairs-old

LAN has assisted our clients and industrial associations with development and understanding of air emission regulations since 1972. Over the past 40 years the U.S. Environmental Protection Agency (EPA) and state environmental agencies have developed regulations pursuant to the Clean Air Act which have dramatically affected the way in which owners of pollutant emission sources operate. It is our experience that the regulated community has inappropriately reacted to many of the regulations due to a lack of understanding of their particular situation. This is due to inadequate resources being appropriated for environmental compliance understanding. In many cases we have been able to reverse this situation due to our being involved with the development of the regulations over the years and having a technical capability to present to the regulatory agencies a clear picture of emissions from a particular source.

Our involvement with the development of regulations has given us appreciation of the process and the technical background utilized for development of these various regulations. Bringing this information forward to our clients in an easy-to-understand and logical presentation has led to a clear methodology by which the regulated community can respond to their particular set of emission standards.

On proposed rulemakings for Standards of Performance for New Stationary Sources (NSPS) and National Emission Standards for Hazardous Air Pollutants (NESHAP) LAN performs an analysis and breakdown of the datacollected from facilities and how EPA utilizes and selectively uses this data for modeling inputs to the risk analysis, setting the MACT floor and requiring new BACT for the proposed rule. LAN’s involvement with this scientific review has included:

Review technical documents on the rulemaking docket

Risk Analysis
Modeling Inputs (EPA’s selective use of data)
Generalized use of assumptions
Emission Estimates/Reductions
Review/critique performance/stack testing reports
We have found considerable errors in support documentation

Lab data
Misinterpretation of data
Analyze EPA Cost Analyses
Review cost-effectiveness for pollution abatement

EPA generally underestimates costs in order to implement their preferred control systems
Mishandling of vendor cost estimates
Misinterpretation of data
Invalid assumptions regarding cost equations