Common use of Permit Applications Clause in Contracts

Permit Applications. The NEC believes that 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, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. 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 is but one example of an applicable requirement that has not been met.

Permit Applications. The NEC believes that 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, and less so, the stationary source’s efforts to comply with complicated regulations. DAQM remains a dysfunctional, air pollution enforcement agency. 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 evaded is but one example of an applicable requirement that has not been met.

Permit Applications. The NEC believes that mostmost stationary sources are honorable, 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, 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, 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 a 1990 amendments SIP is but one example of an applicable requirement that has not been metsufficient to deny the permit.

Permit Applications. The NEC believes that most, if not all stationary sourcessources are honorable, 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. 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 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 one example of an applicable requirement that has not been metsmoke and mirrors.

Permit Applications. The NEC believes that mostmost stationary sources are honorable, 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 was never legally permitted to include requirements for offsets is or LAER are but one example two examples of an applicable requirement requirements that has have not been met.