Book Review: RE Erbes, a Practical Guide to Air Quality Compliance
(1997) 4 Environmental Law and Practice 61-64, 10 Tulane Environmental Law Journal 457-463
Posted: 15 Oct 2020
Date Written: 1997
Erbes, Senior Vice President of a major environmental and engineering consulting firm, has written probably the most useful and comprehensive practice-oriented book on the market on the subject of compliance with air quality controls. The introduction is followed by an informative second chapter detailing the history of air quality legislation. Erbes summarizes the main provisions of federal air quality legislation and concludes with what he terms the “fundamental concepts” of the 1990 Clean Air Act Amendments, specifically, market-based incentives, facility bubbles, compliance certification, intergovernmental requirements, and regulatory negotiation. Market-based incentives include emission trading between different companies. Facility “bubbling” refers to the practice of shifting emissions of air toxins from one device to another within the overall facility to encourage the operator to determine the most cost-effective way to reduce or control emissions levels. For the first time in United States air quality regulation, the Clean Air Act Amendments require a responsible corporate official to certify annually that his plant complies with a permit. In the second chapter, Erbes also introduces regulatory negotiation (reg-neg), an attempt by the Environmental Protection.
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