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June 6, 2018
1:45-2:45PM

Ending the "Once in, Always in" Policy: Reassessing Your MACT Compliance Options

Expo A2

Speakers: Deever Bradley, Partner, ERM; Jeff Holmstead, Partner, Bracewell

Clearly, the reversal of the “once in, always in” policy for MACT applicability presents opportunities for companies to enhance operational flexibility and reduce operating costs and compliance risk. With this policy change, facilities that are able to be permitted as “area sources” under Section 112 will generally be able to reduce the burden of paperwork, monitoring, recordkeeping and reporting requirements and comply with air quality requirements with greater certainty and less headache.

The new policy is promising and deserving of a close examination, and companies will want to carefully develop the best strategies for maximizing the benefits and minimizing any new risks that it may present. ERM and Bracewell will present a one-hour review of the new policy, the problems it solves and the questions and uncertainties that deserve further consideration. This legal and technical team will critically inform your strategies and choices for how to proceed in a world without the “once in, always in” policy.

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2018-06-06 13:45:00 2018-06-06 14:45:00 America/Detroit Ending the "Once in, Always in" Policy: Reassessing Your MACT Compliance Options Speakers: Deever Bradley, Partner, ERM; Jeff Holmstead, Partner, Bracewell Clearly, the reversal of the “once in, always in” policy for MACT applicability presents opportunities for companies to enhance operational flexibility and reduce operating costs and compliance risk. With this policy change, facilities that are able to be permitted as “area sources” under Section 112 will generally be able to reduce the burden of paperwork, monitoring, recordkeeping and reporting requirements and comply with air quality requirements with greater certainty and less headache. The new policy is promising and deserving of a close examination, and companies will want to carefully develop the best strategies for maximizing the benefits and minimizing any new risks that it may present. ERM and Bracewell will present a one-hour review of the new policy, the problems it solves and the questions and uncertainties that deserve further consideration. This legal and technical team will critically inform your strategies and choices for how to proceed in a world without the “once in, always in” policy. Expo A2