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Rich demonstrated his expertise in the convoluted debate about how to make the MACT regulations equitable. His firm represents PCA and has presented EPA with many reasons why changes should be made to the proposed rule. He challenged the fundamental approach used by EPA to use HAP regulations to achieve reductions in PM and SO2. He points out that the primary benefit of setting a low HCl limit is not to reduce the HCl but to reduce SO2 and the ambient sulfates. |
