Tag Archives: State Implementation Plans (SIPs)

Opposition to the Startup, Shutdown & Malfunction Rule Cites EPA’s Breach of Cooperative Federalism Principles and Private Deal-Making with Sierra Club

By Latham & Watkins LLP on June 11, 2013 Posted in Environmental Regulation

By Claudia O’Brien and Karl Karg In the wake of EPA’s proposed rule to force 36 states to revise their state implementation plans (SIPs) to control emissions during periods of startup, shutdown and malfunction (SSM Rule), a number of states filed comments objecting to EPA’s approach as heavy-handed and contrary to the cooperative federalism scheme … Continue Reading