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Clean Air Act Compliance and Enforcement 2018: ODS, CAA §114 Requests, NSR, SSM

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, February 27, 2018

Recorded event now available

or call 1-800-926-7926

This CLE course will provide guidance to counsel on a variety of Clean Air Act (CAA) topics and how they may change, or not, under the new Administration, including New Source Review (NSR), Startup, Shutdown and Malfunction (SSM), ozone depleting substances, enforcement, including Section 114 requests, and more.


The prior Administration issued numerous CAA regulations impacting day-to-day compliance obligations and undertook enforcement initiatives that are now being revisited by the new Administration. For example:

•    Whereas the prior Administration continued the long-running NSR enforcement initiative involving numerous industries, issuing lots of Section 114 information requests, the new Administration is focused on NSR reform and recently issued new guidance to provide greater clarity for NSR compliance.

•    The prior Administration issued a final rule 2015 recalling previously EPA-approved regulations in over half the states governing excess emissions at industrial facilities of all types during startup, shutdown and malfunction events on the basis that they are inconsistent with the CAA. The new Administration may reconsider that action.

•    The prior Administration also undertook a significant expansion of Ozone Depleting Substance (ODS) requirements and expanded enforcement of the ODS requirements.

On the enforcement front, EPA has historically made broad use of its information collection authority under Section 114 of the Act to gather information to support enforcement actions.  With the change in administrations, EPA is still issuing these requests and counsel for regulated industries can benefit from the practical experience of those who know the law and the process well. 

Listen as our experienced panel discusses what to expect in 2018 on all of these issues and how best to respond.



  1. New Source Review Enforcement versus Regulatory Reform
  2. Clean Air Act §114 Requests
  3. Ozone Depleting Substances
  4. Startup, Shutdown and Malfunction


The panel will review these and other key issues:

  •  What can we expect on NSR reform?
  •  How might enforcement change and how to respond to Section 114 requests?
  • Status of ODS regulation and enforcement.
  •          What to expect on SSM regulation?


Campbell, Margaret
Margaret C. Campbell

Troutman Sanders

For over 20 years, Ms. Campbell’s practice has focused primarily on matters arising under the Clean Air Act and...  |  Read More

Hines, Robert
Robert L. (Buzz) Hines

Farella Braun + Martel

Mr. Hines has practiced environmental law for more than 25 years representing clients in complex governmental and...  |  Read More

McGuffey, Mack
Carroll W. (Mack) McGuffey, III

Troutman Sanders

Mr. McGuffey practices environmental law as a partner, specializing in regulatory compliance and enforcement defense...  |  Read More

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