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Policy Updates (12/28/99)

On December 21, 1999, EPA published four Question and Answer documents providing guidance for implementing various aspects of Part 75. EPA published questions and answers from the October, 1999 Part 75 Implementation Conference and the November, 1999 User’s Group Meeting. Another document specifies revisions to Questions 5.6, 13.4, 13.5 and 13.6 of the revised Acid Rain Program Policy Manual issued in October, 1999. Another document introduces five new questions to the Policy Manual. These documents have been bundled into a zipped file available from our FTP Library.

Curiously, EPA did not formally incorporate many of the questions and answers from the October and November meetings into the "new" questions document. Unfortunately, this approach tends to hamper compliance by spreading "policy" throughout various documents and may lead to debate as to whether this guidance is "official."

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RMB Consulting & Research, Inc.
Last Revised: December 28, 1999