• Negotiated two separate exemptions from air quality permit
requirements for a wood-fired boiler project under extreme time constraints.
• Counseled a group of Alaska North Slope petroleum companies regarding
comments on EPA’s proposed MACT standard for stationary combustion turbines.
On March 5, 2004 EPA issued a final rule incorporating the strategy advanced
by ELN.
• Advised and represented a petroleum refinery in process for issuance of
the first Title V air operating permit for a refinery in Washington State.
• Advised clients regarding environmental permitting for energy generating
facilities, including temporary diesel electric engines, gas combustion
turbines, and coal plants.
• Obtained a formal withdrawal of an EPA Administrative Complaint alleging
violation of opacity standards by a ship.
• Defended a cruise line in responding to multiple allegations of opacity
violations.
• Advised a regional trade association and its members on implementation of
complex "Maximum Achievable Control Technology" requirements for hazardous
air pollutants in Title V air operating permits. Assisted in negotiation of
permit terms with state and local permit writers and EPA.
