Phase II is scheduled for proposal in March, with anticipated adoption in July. Staff hopes for proposal of Phase III in March or April. Staff is working on a strategy to address the stacking of standard exemptions at facilities. They are looking for comments regarding whether or not issues currently exist and how to prevent an issue from occurring. A Title V review is slowly beginning as well.
Staff sees volumes and volumes of code citations associated with each permit.
They want to re-examine the purpose of Title V, asking if Title V is really effective. Staff hopes to reduce the burden of Title V by using the concept of new resource review and possibly creating a cap concept for sites. Another concept would use more extensive monitoring requirements. The Innovation Committee of ECOS , headed by Commissioner Marquez, will also be looking at these ideas. Final concepts would then be presented to EPA for consideration.