Legal Challenge to U.S. EPA's December 13, 2005 Final Memo Ruling on BACT and LAER Determinations for New Coal Plants. EPA issued a final ruling asserting that integrated gasification combined cycle (IGCC) technology need not be considered by states in their determination, as part of the air permitting process, of BACT or LAER air emissions rates for new coal plants. CATF challenges this final action as unlawful.
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Letter to Administrator Stephen Johnson, requesting that he immediately withdraw the Final Memo Ruling
February 8, 2006
CATF filed this letter outlining the substantive and procedural reasons why the December 13, 2005 Final Memo Ruling is illegal, and asking the administrator immediately to withdraw it.
List of Appendices to Johnson Letter:- IGCC BACT Final
- E3 IGCC BACT
- Hedges Email
- ELR.Foote
- Hard copy only from Agency
- CC Air Permit Applications
- Elm Road Air Permit
- Lowe GE
- Ron Heranek
- George Booras
- Taylorville IGCC Feasit
- Wayland GTC IGCC Tucson
- Bob Wayland
- Cipriano Letter
- Sutton IEPA IGCC Letter
- ORDER KEY Hearing Officer
- BER Proposed Findings
- NM Response
- NMED Letter to Peabody Energy
- Long View Resp Comments
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Petition for Review of the Final Memo Ruling Filed by CATF in the D.C. Circuit on February 13, 2006, on behalf of Sierra Club, Ohio Environmental Council, American Lung Association of Metropolitan Chicago, Valley Watch, Inc.
February 13, 2006
CATF initiated a legal challenge on behalf of four environmental groups, seeking to have EPA's December 13, 2005 Final Memo Ruling vacated and withdrawn.
