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This 2015 SIP Call rule focused on the treatment of excess emissions during periods of startup, shutdown, or malfunction (SSM). K Startup and Shutdown, in its place. Essentially, EPA noted that Louisiana’s rules “may be read so as to create situations wherein startup and shutdown emissions are functionally exempt[.]” LAC 33:III.2201.K
Amidst historically low oil prices and economic shutdowns, fossil fuel companies continue to defend against lawsuits brought by state and local governments claiming climate-change related damages. 1442(a)(1). In City of Oakland et al. 1442(a)(1). 1442(a)(1).
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