State Implementation Plans (SIPs)

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 of the Clean Air Act (the Act).  Claudia O’Brien and Karl Karg have written a blog entry describing the rule, the controversial rulemaking process, and