Baker & McKenzie

Assuring Compliance With Air Emissions Limits

THE U.S. ENVIRONMENTAL PROTECTION AGENCY HAD A novel idea: For power plants and sources relying on devices to control air emissions, rather than attempt to monitor the actual physical emissions to determine compliance with federal law, it simply would require inspections and tests of the performance of the control device. %n1%n

This strategy was formalized in the EPA's compliance assurance monitoring (CAM) rule signed Oct. 17, 1997. The EPA's theory is that if the control device is working properly, it is likely pollutant emissions fall within the required limits.