Permit Applications. The NEC believes that most stationary sources are honorable, law-abiding companies that are misled by DAQM regarding CAA responsibilities. The focus of this comment is on regulator malfeasance and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. DAQM is an agency of fluff over substance, quantity over quality, and personal paychecks over integrity. Regarding the requirement for compliance certification found at 40 CFR §70.5(c) (9) (i), “A certification of compliance with all applicable requirements by a responsible official consistent with paragraph (d) of this section and section 114 (a) (3) of the Act” is required.” Paragraph (d) of the section states the requirement that “This certification and any other certification required under this part shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” Neither DAQM nor the Source has lawfully fulfilled the certification requirements. Neither the source nor the DAQM can comply with the certification requirement and that is probably the reason the certification is missing. DAQM does not have any idea what SIP or SIP regulations they are attempting to comply with. That responsibility lies with DAQM, the State of Nevada and the EPA. Without compliance with “all applicable requirements,” and without approved SIP rules, statements of compliance mislead. The fact that the site was never legally permitted to include requirements for offsets or LAER are but two examples of applicable requirements that have not been met.
Appears in 1 contract
Samples: Title v Operating Permit Comments
Permit Applications. The NEC believes that most most, if not all stationary sources are honorable, law-abiding companies that are misled by DAQM regarding CAA responsibilities. The focus of this comment is on regulator malfeasance malfeasance, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. DAQM is an agency of fluff over substance, quantity over quality, and personal paychecks over integrity. Regarding the requirement for compliance certification found at 40 CFR §70.5(c) (9) (i), “A certification of compliance with all applicable requirements by a responsible official consistent with paragraph (d) of this section and section 114 (a) (3) of the Act” is required.” Paragraph (d) of the section states the requirement that “This certification and any other certification required under this part shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” ”. Neither DAQM nor the Source has lawfully fulfilled the certification requirements. Neither the source nor the DAQM can comply with the certification requirement and that is probably the reason the certification is missing. DAQM does not have any idea what SIP or SIP regulations they are attempting to comply with. That responsibility lies with DAQM, the State of Nevada and the EPA. Without compliance with “all applicable requirements,” and without approved SIP rules, statements of compliance mislead. The fact that the site CO concentration limits are missing from the permit indicates the source was never legally permitted in compliance with BACT in the PSD area. Add to include requirements for offsets or LAER are that the source’s existing part 70 permit has expired without enforcement action and it is clear that the Xxxxx County permitting program is nothing but two examples of applicable requirements that have not been metsmoke and mirrors.
Appears in 1 contract
Samples: Title v Operating Permit Comments
Permit Applications. The NEC believes that most most, if not all stationary sources sources, are honorable, honorable law-abiding companies that are misled by DAQM regarding CAA responsibilities. The focus of this comment is on regulator malfeasance malfeasance, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. DAQM is an agency of fluff over substance, quantity over quality, and personal paychecks over integrity. Regarding the requirement for compliance certification found at 40 CFR §70.5(c) (9) (i), “A certification of compliance with all applicable requirements by a responsible official consistent with paragraph (d) of this section and section 114 (a) (3) of the Act” is required.” Paragraph (d) of the section states the requirement that “This certification and any other certification required under this part shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” ”. Neither DAQM nor the Source has lawfully fulfilled the certification requirements. Neither the source nor the DAQM can comply with the certification requirement and that is probably the reason the certification is missing. DAQM does not have any idea what SIP or SIP regulations they are attempting to comply with. That responsibility lies with DAQM, the State of Nevada and the EPA. Without compliance with “all applicable requirements,” and without approved SIP rules, statements of compliance mislead. The fact that the site was never legally permitted to include requirements for offsets or LAER are is but two examples one example of an applicable requirements requirement that have has not been met.
Appears in 1 contract
Samples: Title v Operating Permit Comments
Permit Applications. The NEC believes that most most, if not all stationary sources sources, are honorable, honorable law-abiding companies that are misled by DAQM regarding CAA responsibilities. The focus of this comment is on regulator malfeasance malfeasance, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. DAQM is an agency of fluff over substance, quantity over quality, and personal paychecks over integrity. Regarding the requirement for compliance certification found at 40 CFR §70.5(c) (9) (i), “A certification of compliance with all applicable requirements by a responsible official consistent with paragraph (d) of this section and section 114 (a) (3) of the Act” is required.” Paragraph (d) of the section states the requirement that “This certification and any other certification required under this part shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” ”. Neither DAQM nor the Source has lawfully fulfilled the certification requirements. Neither the source nor the DAQM can comply with the certification requirement and that is probably the reason the certification is missing. DAQM does not have any idea what SIP or SIP regulations they are attempting to comply with. That responsibility lies with DAQM, the State of Nevada and the EPA. Without compliance with “all applicable requirements,” and without approved SIP rules, statements of compliance mislead. The fact that the site pre-construction monitoring was never legally permitted to include requirements for offsets or LAER are evaded is but two examples one example of an applicable requirements requirement that have has not been met.
Appears in 1 contract
Samples: Title v Operating Permit Comments
Permit Applications. The NEC believes that most stationary sources are honorable, law-abiding companies that are misled by DAQM regarding CAA responsibilities. The focus of this comment is on regulator malfeasance malfeasance, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. DAQM is an agency of fluff over substance, quantity over quality, and personal paychecks over integrity. Regarding the requirement for compliance certification found at 40 CFR §70.5(c) (9) (i), “A certification of compliance with all applicable requirements by a responsible official consistent with paragraph (d) of this section and section 114 (a) (3) of the Act” is required.” Paragraph (d) of the section states the requirement that “This certification and any other certification required under this part shall state that, based on information and belief formed after reasonable inquiry, the statements and information in the document are true, accurate, and complete.” Neither DAQM nor the Source has lawfully fulfilled the certification requirements. Neither the source nor the DAQM can comply with the certification requirement and that is probably the reason the certification is missing. DAQM does not have any idea what SIP or SIP regulations they are attempting to comply with. That responsibility lies with DAQM, the State of Nevada and the EPA. Without compliance with “all applicable requirements,” and without approved SIP rules, statements of compliance mislead. The fact that the site was never legally permitted pursuant to include requirements for offsets or LAER are but two examples of applicable requirements that have not been meta 1990 amendments SIP is sufficient to deny the permit.
Appears in 1 contract