OCR Text |
Show The I C C R process has framed several important issues that the E P A must address to produce good regulations for industrial combustion equipment. These include: the critical importance of a working definition for solid waste, the issues regarding application of pollution prevention techniques in the regulations, and the issues of establishing M A C T floor when emissions vary by orders of magnitude on apparently similar pieces of combustion equipment These accomplishments have produced a solid foundation on which the EPA can build and finalize the regulations for HAPs. On the other hand, the dialogue was often impeded by an unwillingness of affected stakeholders to compromise on what seemed to be minor issues. The E P A did not renew the I C C R charter because the progress was too slow to meet the deadlines for promulgation of the M A C T standards. The agency also indicated that the process was too expensive. However, the dialogue also enabled the stakeholders to understand opposing viewpoints and to refine their positions. This often resulted in superior work products for use in the regulatory process. Most participants in the ICCR agree that the process was worthwhile. This process should be considered for future rulemakings with modifications that would promote more rapid progress. A possible modification would be to limit the time period for discussion and dialogue. If the parties involved in the dialogue cannot reach consensus within a given time period, they should have to present their respective positions for judgment by the E P A and the process should continue to the next item on the critical path. C:\jps\iccr\overviewa 9 |