Please think about how COMS can be used to prove violations in citizen enforcement actions. Require the regulated entity keep records and report results to state agencies. If the regulated entities certify the accuracy of their reports, then they should not be able to challenge the accuracy of these reports during a citizen suit. Also require that the regulated entities report malfunctions of the COMS if they want to claim inaccurate reports.
Anonymous public comment
This is comment on Proposed Rule
Standards of Performance for Fossil-Fuel-Fired, Electric Utility, Industrial-Commercial-Institutional, and Small Industrial-Commercial-Institutional Steam Generating Units; Proposed Rule
View Comment
Related Comments
Public Submission Posted: 01/24/2011 ID: EPA-HQ-OAR-2005-0031-0289
Feb 22,2011 11:59 PM ET
Public Submission Posted: 02/23/2011 ID: EPA-HQ-OAR-2005-0031-0290
Feb 22,2011 11:59 PM ET
Public Submission Posted: 02/23/2011 ID: EPA-HQ-OAR-2005-0031-0291
Feb 22,2011 11:59 PM ET
Public Submission Posted: 02/23/2011 ID: EPA-HQ-OAR-2005-0031-0292
Feb 22,2011 11:59 PM ET
Public Submission Posted: 02/23/2011 ID: EPA-HQ-OAR-2005-0031-0293
Feb 22,2011 11:59 PM ET