• American Electric Power Company�s (AEP�s) Motion for a Stay, Filed in the Southern District Court in Ohio (November 10, 2005) -- AEP bases the motion on: 1) the pending Sixth Circuit Court of Appeals decision in National Parks Conservation Ass�n v. TVA on whether NSR cases (or counts in them) that cover modifications made more than five years ago should be dismissed on the grounds that they violate the five year federal statute of limitations (28 U.S.C. sec. 2462); and 2) the �legal impact of official rulemaking statements� in the PSD/NSPS EGU rule proposed October 20, 2005.
   
• Cinergy Corporation�s Motion for Summary Judgment in the �NSR Enforcement Initiative� Case (November 9, 2005) -- This motion was filed in 1999 by EPA.  The accompanying Memorandum is a detailed history of EPA decisions on applicability of NSR throughout the years that Cinergy cites in support of its argument that it had no fair notice of the legal interpretation that EPA is now making in its NSR PSD/EGU rule proposed on October 20, 2005.
   
• U.S. Court of Appeals Decision in NY PIRG v. Johnson on Title V Operating Permits Case (October 24, 2005) -- In this case, the U.S. Court of Appeals for the Second Circuit held that EPA should have granted NYPIRG�s petition to reconsider the Title V operating permits for two New York power plants when the New York Department of Environmental Conservation had previously issued a detailed Notice of Violation for the power plants setting forth violations of PSD requirements to install pollution control equipment and obtain permits when modifying and replacing equipment.
   
• D.C. Circuit Court of Appeals decision in Environmental Integrity Project v. EPA (October 14, 2005) -- Court vacated EPA�s �Umbrella� Monitoring Rule on the grounds that the final rule (2004) was not a logical outgrowth of the proposed rule (2002). Until EPA promulgates a rule in accord with notice and comment procedures, states that do not have their own statutory provisions for supplementing inadequate periodic monitoring are able to add requirements for such monitoring in Title V permits.
   
• Cinergy Case's Grant of Interlocutory Appeal in NSR Case (October 4, 2005)
   
• Center for Biological Diversity's Lawsuit Against EPA on Reevaluation and Revision of NOx Standard (September 16, 2005) -- This lawsuit seeks EPA reevaluation and revision of the nitrogen dioxide standard in accord with section 109(d)(1) of the Clean Air Act, which requires examination and reevaluation of the NAAQS every five years.
   
• STAPPA and ALAPCO Comment on Startup, Shutdown, Malfunction Plan Reconsideration (September 13, 2005)
   

• Fourth Circuit Refuses to Reconsider Duke Energy Holding (August 31, 2005) -- The Fourth Circuit Court of Appeals has denied EPA�s request for a hearing by the full panel of judges or, alternatively, a rehearing by the same panel that rendered the decision. This leaves standing the decision by the Court that new source review requirements are triggered only when there is an increase in the hourly rate of emissions, rather than an increase in actual annual emissions.
   

• Opinion Denying Cinergy's Summary Judgment Motion in NSR Case (August 30, 2005) -- On August 29, the Southern District Court in Indiana specifically disagreed with the Fourth Circuit Court of Appeals� interpretation of what constitutes a modification for purposes of new source review (NSR), holding that significant actual annual increases in emissions necessitate NSR requirements of permitting and installation of pollution controls. The opinion denied Cinergy�s summary judgment motion, filed by the company following the Duke decision.
   

• Duke Energy Petition for Rehearing on NSR Case (August 18, 2005)
   

• Kentucky Officer's Report and Recommendation in Thoroughbred Generating Company Case (August 15, 2005) --  The hearing officer recommended that the Kentucky Division of Air Quality reconsider BACT for the generating station, including IGCC and coal washing, in addition to other recommendations relating to the fact that the proposed location would impact a PSD Class I area, Mammoth Caves.
   

• EPA�s Response to Comments on AFO Safe Harbor Agreement (June 23, 2005)
   

• EPA Web Site on AFO Safe Harbor Agreement (June 23, 2005)
   

• STAPPA/ALAPCO/EPA Enforcement and Compliance Workshop Presentations (June 20, 2005)
   
• Fourth Circuit Court of Appeals Opinion in EPA v. Duke Energy (June 15, 2005) -- The Court of Appeals upheld the federal district court�s decision that there is no modification unless there has been an increase in the hourly rate of emissions, or capacity. The case, which now binds the five states in the Fourth Circuit, concluded that the definition of modification for NSR purposes must be identical to that of NSPS. Note that the recent DC Circuit Court of Appeals decision on the 2002 NSR rules adopted contrary reasoning and conclusions on this issue.
   
• Draft STAPPA/ALAPCO Comments on EPA�s Advance Notice of Public Rulemaking (ANPR) on Potentially Inadequate Monitoring (June 10, 2005) -- Please send any suggestions for changes to Mary Stewart Douglas at mstewartdouglas@4cleanair.org by Monday, June 13 at noon. Note that the filing deadline, should you wish to submit comments from your agency, is June 17.
   
• Court's Decision on Alabama Power NSR/PSD Case (June 10, 2005) -- This is the Alabama Power decision, in which the Northern District Court of Alabama, Southern Division, concluded that modifications made by the company�s electrical generating plants were not subject to NSR/PSD requirements because they were �routine.�  The Court concluded that EPA should not benefit from Chevron deference to its interpretation of �routine maintenance� because of the agency�s inconsistent positions over the years since the WEPCO decision by the Seventh Circuit Court of Appeals.  Alabama Power aligns with the reasoning of Duke Energy, both of which determined that �routine� should be judged by comparison to the industry as a whole, rather than a particular unit, and, further, that emissions increases should be based on whether there is an increase in the hourly rate of emissions rather than total tons per year.
   
• Lawsuit on EPA AFO Safe Harbor Agreement (June 2, 2005) � This petition to review was filed in the U.S. Court of Appeals for the D.C. Circuit by the Environmental Integrity Project, the Sierra Club, Iowa Citizens for Community Improvement and the Association of Irritated Residents challenging EPA�s proposed Air Quality Compliance Agreement for Animal Feeding Operations.  Click here for a press release.
   
• STAPPA/ALAPCO Spring Membership Meeting Presentations (June 1, 2005)
   
• STAPPA/ALAPCO�s Comments on EPA�s Proposal to Exempt from Title V Permitting Five Area Source Categories that are Subject to NESHAPS (May 26, 2005) --  These comments supporting EPA�s exemption of five area source categories from Title V permitting requirements were filed May 24, 2005.  The associations urged EPA to finalize the exemptions expeditiously and also stated that EPA should not require rescission of existing Title V permits in cases in which states or localities may have already issued them.  Rather it should be the choice of state and local agencies whether to require Title V�or general�permits for these sources.  
   
• U.S. District Court Decision to Postpone the American Electric Power New Source Review Trial (May 13, 2005)
   
• Presentation on Title V and NSR  EPA�s Bill Harnett at the CAAAC Meeting (April 7, 2005)
   
• NSR Interim Guidance for PM2.5 Nonattainment Areas (April 5, 2005)
   
• STAPPA/ALAPCO Comments on Title V (March 31, 2005) -- These comments were submitted by STAPPA and ALAPCO for the consideration of the Title V Task Force as it drafts recommendations for revising Title V that will be reviewed by EPA.  The associations urged streamlining of Title V requirements relating to insignificant emissions units, focus by the Task Force on how best to incorporate MACT standards into permits, encouragement of public process requirements when interest in high�but relaxation of such requirements when it is not, and various other changes.
   
• Nine States Challenge EPA Mercury Rule (March 30, 2005) -- This lawsuit filed by California, Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New Mexico, New York, and Vermont in the U.S. Court of Appeals for the District of Columbia challenges EPA�s cap-and-trade approach to regulating mercury emissions from electric utilities.  EPA�s rule rescinds the findings made in 2000 on mercury that supported a requirement that utilities should install the maximum achievable control technology, or MACT, defined under the Clean Air Act as the average of the best-performing 12 per cent of sources in an industry category.  Instead, the current rule states, �[B]y this action, we are revising the December 2000 appropriate and necessary finding and concluding that it is neither appropriate nor necessary to regulate coal- and oil-fired Utility Units under section 112.�  EPA final Mercury Rule was published Wednesday, March 15. Click here to view it.
   
• New York, Connecticut and New Jersey Press Release Announcing the Settlement of the Ohio Edison NSR Case (March 28, 2005)
   
• Proposal to Exempt Area Sources Subject to NESHAP from Federal and State Operating Permit Programs (March 25, 2005) -- This proposed rule would exempt five area source NESHAPs categories from Title V permitting requirements.  Deferrals from permitting requirements expired December 9, 2004.
   
• EPA and Ohio Edison Settlement on NSR Case (March 18, 2005)
   
• �Request for Comment on Potentially Inadequate Monitoring in the Clean Air Act Applicable Requirements and on Methods to Improve Such Monitoring.�  (March 4, 2005) -- This advance notice of proposed rulemaking (ANPR) asks for identification of all deficient pre-1990 NSPS and NESHAPS standards as well as any deficient monitoring in State Implementation Plans (SIPs). EPA lists �categories of potential monitoring inadequacies� based on its preliminary review of certain NSPS and NESHAPS rules and sets these categories out in Part IV of the ANPR.�
   
• Substantial Changes Needed in Implementation and Oversight of Title V Permits If Program Goals Are to be Fully Realized (March 11, 2005) --  This EPA OIG report was based on an examination of forty Title V permits in four states.  It concludes that permit clarity, monitoring, statements of basis, and annual compliance certifications varied significantly across permitting authorities and need improvement.  The OIG also found that overly general monitoring and testing requirements potentially affected the practical enforceability of some of the permits. The report recommends that EPA issue nationwide guidance on statement of basis and annual compliance certifications, a recommendation not embraced by EPA.  Other specific recommendations were made at the end of each chapter.
   
• EPA and Illinois Power Company Settlement on NSR Violation (March 8, 2005) -- This is EPA�s press release describing the settlement of its new source review case against Illinois Power.  The consent decree calls for expenditures on pollution controls totally $500 million at 5 power plants and provides as well for SEPs and a penalty amount.
   
• STAPPA/ALAPCO Comments on EPA's Proposal to Include Additional Data Elements in ICR ( March 7, 2005) -- These comments were submitted to the EPA's docket on March 7, 2005   The associations stated that, although the national consensus was that there be no new data reporting requirements, that the Subpart Identifier and 60-day time frame for reporting would be acceptable.
   
• Iowa DNR Comments on EPA Air Quality Compliance Agreement for AFOs (March 4, 2005)
   
• STAPPA/ALAPCO Comments on EPA Air Quality Compliance Agreement for AFOs (March 3, 2005)
   
• EPA SEP Toolkit (February 17, 2005) -- This toolkit helps state and local governments pursue new energy efficiency or renewable energy projects through enforcement settlements. The toolkit presents the case for pursuing energy efficiency and renewable energy within settlements, provides examples and ideas for projects, and provides a step-by-step regulatory �road map� for pursuing SEPs.
   
• New York PSD Settlements (February 10, 2005) -- This presentation was given by the State of New York in our January 27 Committee call. It sets forth the terms of the PSD settlements between New York and two major utilities, AES and NRG, including the emissions reductions achieved.
   
• EPA Technical Support Document Justifying ICR for Compliance-Related Data (February 4, 2005) --  EPA has released the technical support document that justifies an ICR that increases the compliance-related data reporting requirements for state and local agencies. Titled �Agency Information Collection Activities: Request for Comments on Source Compliance and State Action Reporting Proposed Information Collection Request (ICR) Number 0107.08, OMB Control Number 2060-0096,� the request for comment sets forth new requirements for mandatory reporting of on-site partial compliance evaluations (PCEs), a requirement that data be reported every 60 days (as opposed to the former quarterly time frame), and other data elements:  The ICR is now being considered by OMB.  Comments filed in EPA�s electronic docket system will go to OMB.  All comments are due by March 7, 2005. Click here of information on how to file comments.
   
• EPA Air Quality Compliance Agreement for AFOs (January 21, 2005) -- This agreement provides a safe harbor from enforcement by EPA of certain Clean Air Act, CERCLA and EPCRA provisions for participating AFOs in exchange for the AFOs paying a small penalty and contributing funding for a monitoring program. Comments are due by March 2, 2005. Click here for the monitoring protocol. Click here for the January 31st Federal Register notice. Click here for a fact sheet. Click here for a link to a Q&A prepared by the National Pork Producers Council on the agreement. EPA has extended the comment period to May 2, 2005 and the sign-up period to July 1, 2005; click here for this notice. Click here for an EPA presentation on the agreement.
   
• National Academy of Sciences' Interim Report on NSR (January 13, 2005) -- The National Academy of Sciences today released it Interim Report on the new source review (NSR) reforms that were promulgated on December 31, 2002 and October 27, 2003.  The Committee on Changes in New Source Review Programs for Stationary Sources states, �As it carries out its charge, the Committee is considering a number of relevant scientific and technical documents prepared by EPA, other federal agencies, industry, environmental and nongovernmental organizations. The Committee expects to provide its perspective on several of these documents in its final report.�  The final report will be published in late 2005. Meanwhile, the Committee concludes (page 17) that �[I]n general NSR provides more stringent emission limitations for new and modified major sources than do the EPA programs [CAIR and Clear Skies].�  The Committee notes that it heard testimony from many witnesses in hearings held in May, including William Becker representing STAPPA and ALAPCO.
   
• STAPPA and ALAPCO Unopposed Joint Motion for Leave of Court to File Brief Amicus Curiae in NRDC and Sierra Club Plywood MACT Case (December 1, 2004)
   
• North Carolina Attorney General's Letter Announcing Intention to Sue TVA (November 19, 2004) -- This letter was sent on November 10, 2004 by Roy Cooper, Attorney General of North Carolina, to EPA and state officials in Alabama, Kentucky, and Tennessee. It states that North Carolina intends to sue the Tennessee Valley Authority (TVA) for new source review violations at coal-burning power plants in those three states, including failure to seek NSR permits and failure to install best available pollution control equipment.
   
• STAPPA/ALAPCO Fall 2004 Membership Meeting Presentations (October 29, 2004)
   
• Environmental Integrity Project Report : "Gaming the System" (August 18, 2004) -- This report focuses on emissions from malfunctions in 29 states and their often startlingly large contribution to total emissions of various pollutants.
   
• EPA Inspector General Office's  Evaluation of NSR Rule Changes (October 4, 2004) -- This is the EPA Inspector General�s report that concludes that the Equipment Replacement Provision (ERP) promulgated October 27, 2003 has hampered EPA NSR enforcement and compromised settlements in existing NSR cases.
   
• EPA's Brief in EPA v. Duke Energy (September 9, 2004) -- EPA filed this brief on September 3 in the U.S. Court of Appeals for the Fourth Circuit in United States v. Duke Energy Corporation.  The appeal from last summer�s summary judgment decision by the Middle District Court of North Carolina states that annual emissions, rather than an increase in the rate of hourly emissions, should be the trigger for new source review (NSR) applicability.  It further asserts that whether or not activities are or are not �routine maintenance� should be judged by what is �routine� for the unit in question, rather than with regard to industry practices.
   
• Brief of Environmental Intervenor-Respondents (August 30, 2004) -- This brief was filed by the environmental intervenor-respondents in the New York v. EPA case filed in the U.S. Circuit Court of Appeals for the District of Columbia.  The case claims that the new source review (NSR) provisions promulgated by EPA on December 31, 2002 are unlawful under the Clean Air Act.  This brief, filed by the Natural Resources Defense Council, the Clean Air Trust, and Earthjustice, argues that the industry brief filed in August 2004 is wrong in asserting that only an increase in the hourly rate of emissions triggers NSR, and that the legislative history of the Clean Air Act demonstrates that an actual increase in emissions triggers NSR requirements for permitting and installation of pollution control equipment.
   
• STAPPA/ALAPCO Comment on EPA's Equipment Replacement Rule Reconsideration (August 30, 2004) -- STAPPA and ALAPCO submitted comments to EPA in response to EPA�s July 1, 2004 Notice of Reconsideration, 40 CFR Parts 51 and 52 �Prevention of Significant Deterioration (PSD) and Non-Attainment New Source Review (NSR): Equipment Replacement Provision of the Routine Maintenance, Repair and Replacement Exclusion; Reconsideration.�  Specifically, the associations stated that they strongly oppose the Equipment Replacement rule and believe that if implemented, it will allow many industrial and utility sources of air pollution to modify their process equipment and increase emissions of pollutants without NSR permitting, air quality analysis or installation of pollution control equipment. The associations further stated that they advocate development of a list of routine and non-routine activities that would clarify the �routine maintenance� exception.
   
• EPA's AFS Business Rules Compendium (August 23, 2004) -- This compendium was compiled in 2003 via the collaborative efforts of the EPA Regions and Users of AFS.  It is intended to be a living document, to change when the air compliance/enforcement program changes, and when the AFS changes. The document was finalized in May 2004.
   
• EPA's AFS Business Rules Guidance (August 23, 2004) -- This guidance provides the AFS user with instructions for data entry of Clean Air program activity in the Air Facility System (AFS). Required data entry is outlined in the Summary of National Minimum Data Requirements (MDRs) for Clean Air Act Stationary Source Compliance, a document contained in the Information Collection Request (ICR) approved by the Office of Management and Budget. This document is not intended to add or change any data requirements.
   
• STAPPA/ALAPCO Comments on ICR for AFS Data (August 3, 2004) -- The associations advocate continuing the present optional reporting of partial compliance evaluation (PCE) data rather than a mandatory system, and oppose required reporting on a 30-day rather than quarterly basis.
   
• Information Collection Request on the AFS Data (July 12, 2004) --  Comments are due August 2.  We encourage all programs to comment on the burdens that they would incur if they were required, as the notice proposes, to report all partial compliance evaluations (PCEs) as well as to report on a monthly rather than quarterly basis.  Other reporting requirements, such as reporting stack test pollutants and Title V information, may also pose problems for individual programs.
   
• CAPCOA's White Paper on AFOs and CAFOs (July 12, 2004) -- For those of you considering adopting regulatory programs that would require emissions from AFOs and CAFOs to be permitted under Title V and NSR, Doug Quetin, Co-Chair of the STAPPA/ALAPCO Agriculture Committee, notes that a White Paper developed by California may be helpful. The legislation enacted last summer by California that requires T V and NSR permitting for AFOs and CAFOs can also be found on the page. 
   
• EPA Inspector General�s report on EPA�s refinery enforcement effort (July 7, 2004) -- The report criticizes OECA�s failure to adequately define and implement goals for improving compliance in this industry sector and notes that OECA should also improve its efforts to monitor the consent decrees that it has entered into with various refineries. Although the report praises the eight-year effort for improving practices such as leak detection and flaring in 40% of the industry, it takes OECA to task for uneven management practices and follow-through.
   
• STAPPA/ALAPCO/EPA Enforcement and Compliance Workshop Presentations (June 17, 2004)
   
• NESCAUM's Analysis of EPA's Changes to RMRR (June 2004) -- This Northeast States for Coordinated Air Use Management (NESCAUM) report quantifies potential emission increases in New England associated with EPA�s proposed changes to the New Source Review (NSR) routine maintenance, repair and replacement rule (RMRR) (�the Equipment Replacement rule�). The report concludes that, �New England�s unenviable position at the end of the nation�s �tailpipe� will result in the Northeast bearing the brunt of the emissions increases that do occur as a result of EPA�s NSR changes.� The report examines publicly available permits, emissions inventories and compliance information to determine allowable and actual emission levels at 308 facilities in six states.
   
• Northeast States Sue Alleghany Energy, Inc (May 21, 2004) -- This is the Notice of Intent to Sue under CAA Section 7604 Letter that was sent to Alleghany Energy Supply Company on May 20 by the States of New York, Connecticut, New Jersey, and Pennsylvania.  The letter alleges that modifications were made at several facilities without PSD permitting or installation of BACT, and that significant increases in emissions resulted from the modifications.
   
• The Supreme Court�s denial of certiorari in the TVA case, which did not address the merits, can be found at Leavitt v. TVA, U.S., No. 03-1162, 5/3/04.  The government�s brief arguing for acceptance of certiorari by the U.S. Supreme Court addressed the questions involving constitutionality of EPA�s administrative orders, the PSD new source review issues, and the status of TVA as a federal power authority.  It can be found at http://www.usdoj.gov/osg/briefs/2003/2pet/7pet/2003-1162.pet.rep.html . For the June 2003 decision of the Eleventh Circuit in TVA v. Whitman, 336 F. 3d 1236, 56 ERC 1737 (11^th Cir. 2003), scroll down to the link in Important Documents.
   
• EPA Working Draft of CAFO Consent Agreement (Safe Harbor) (April 19, 2004) -- This is EPA's working draft of the AFO consent agreement, dated March 11, 2004.
   

• Monitoring Protocol for CAFO Safe Harbor Agreement (Executive Summary) (March 19, 2004) -- These are EPA's recommendations to the CAFO industry for structuring the monitoring under the CAFO safe harbor agreement (which EPA calls the AFO consent agreement).  Under the agreement, the industry is responsible for setting up and running the monitoring program, subject to EPA's approval.  A revised draft of the safe harbor agreement will be shared with us in the next two weeks.
   

• EPA's Final Stack Testing Guidance (March 12, 2004) -- Click here to view the transmittal letter indicating that it is effective on a one-year, interim basis as state and local agencies gain experience with it.
   

• Memorandum of Understanding Between EPA and North Dakota (February 24, 2004)-- This memorandum establishes revisions to the state�s modeling protocol for PSD permitting.
   

• Buckeye Egg -- Proposed Consent Decree (February 24, 2004) -- Under a settlement reached with EPA, Buckeye Egg Farm in Ohio will spend more than $1.4 million to install and test innovative pollution controls to cut emissions of PM and ammonia from its three giant egg-laying facilities and pay an $880,598 civil penalty. Click here for Attachment A regarding emission controls. Click here for a DOJ press release.
   

• DOJ Appeals Tennessee Valley Authority (TVA) NSR Case to Supreme Court (February 23, 2004) -- This is the Petition for a Writ of Certiorari filed in the Supreme Court by the Solicitor General on February 13, 2004.  The petition and supporting statement ask the Supreme Court to review the decision of the Eleventh Circuit Court of Appeals in which the Eleventh Circuit found that the administrative order scheme of the Clean Air Act violated the due process clause of the Constitution.
   

• Draft STAPPA/ALAPCO Letter to EPA on Revised Safe Harbor Agreement (February 2, 2004) -- This is a draft letter from the chairs of the Agriculture Committee to EPA expressing concerns with EPA's revised draft of the safe harbor agreement (also known as the animal feeding operations consent agreement and final order, or AFO CA/FO). If you have any comments or concerns with the letter, please contact Amy Royden at aroyden@4cleanair.org by Monday, February 9.
   

• EPA vs. Kentucky Power Cooperative Inc. (January 29, 2004) -- This is the complaint filed by EPA against the Kentucky Power Cooperative for Violation of Clean Air Act new source review provisions on January 28.
   

• Petition for Reconsideration of December 24, 2001 RMRR Rule (January 23, 2004) -- This petition was filed on January 16, 2004 by several environmental groups challenging the Equipment Replacement rule and seeking reconsideration of the rule, which was promulgated October 27.
   

• Alaska Department of Environmental Conservation (DEC) v. EPA, et. al. (January 21, 2004) -- This is the Supreme Court opinion that established by a 5-4 majority that the Clean Air Act authorized EPA to stop construction of a major pollutant-emitting facility permitted by a state authority when EPA  found that an authority�s BACT determination was unreasonable.  Alaska had issued PSD permits to Teck Cominco�s Red Dog Mine and had alleged that its BACT choice of low-NOx should be upheld on the grounds that the Clean Air Act allows the technology choice to be made by �the permitting authority.�  The Supreme Court, however, upheld EPA�s stop-construction orders and the agency�s choice of selective catalytic reduction.
   

• STAPPA/ALAPCO's Amicus Brief Supporting SCAQMD Fleet Rules (January 15, 2004) -- On November 17, 2003, STAPPA and ALAPCO joined six other amici curiae in submitting a brief to the U.S. Supreme Court in support of the South Coast Air Quality Management District (SCAQMD) in the case of the Engine Manufacturers Association and Western States Petroleum Association v. SCAQMD. The issue in this case is whether Section 209(a) of the Clean Air Act preempts rules adopted by SCAQMD in 2000 requiring fleets (15 or more vehicles) purchased or operated under contract with municipalities within the South Coast district to be low- or zero-emissions vehicles from a list of vehicles approved by the California Air Resources Board.  EMA and the Western States Petroleum Association have challenged SCAQMD�s rules, arguing that they are �standards related to the control of new motor vehicles,� and, therefore, preempted by Section 209(a) of the Act.  STAPPA, ALAPCO and the other amici curiae argue in their brief that SCAQMD�s fleet rules are not �standards� preempted by Section 209(a) and that adoption of the petitioners� broad reading of Section 209(a) would erode environmental federalism and jeopardize vital state and local government interests.  The U.S. Supreme Court heard oral argument on this case at 10:00 a.m. on Wednesday, January 14, 2004.
   

• STAPPA and ALAPCO�s comments on EPA�s Preliminary National Enforcement and Compliance Assurance Priorities for Fiscal years 2005, 2006, and 2007 (January 13, 2004)
   

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