Minimizing the risks created by an emissions inventory
- Kane Jorden von Oppenfeld Bischoff & Biskind, P.L.C., Phoenix, AZ (United States)
Emissions inventories are required under the federal Clean Air Act ({open_quotes}Act{close_quotes}). Sources must identify emissions points and the types of air pollutants emitted, and quantify by measurement, modeling, or estimation the amount of each pollutant. The emissions inventory is an information gathering tool, providing regulatory agencies and the public with an overview of pollutants that may be emitted. Emission inventories are not reports of precise measurements of emissions and may be misunderstood, misinterpreted or misused. The emissions inventory and the underlying documentation are potential evidence in enforcement actions under the Act and other federal and state environmental laws. Readily available to the public, emission inventories may also be used in citizen suits, toxic tort actions and other types of civil actions for damages. Practical as well as legal mechanisms allow regulated entities to minimize the possibility that an emissions inventory or its underlying documentation will be a {open_quotes}smoking gun.{close_quotes} Practical tools include use of qualifying or disclaimer language in the final inventory. The inventory effort can be planned and executed to minimize the risk of misuse and to bring the effort within privileges, such as the self-evaluative privilege, statutory audit privileges, the attorney-client privilege or the attorney work product privilege.
- OSTI ID:
- 617928
- Report Number(s):
- CONF-9609223-; TRN: 98:002008-0014
- Resource Relation:
- Conference: Conference on emission inventory: key to planning, permits, compliance and reporting, New Orleans, LA (United States), 4-6 Sep 1996; Other Information: PBD: 1996; Related Information: Is Part Of The emission inventory: Key to planning, permits, compliance, and reporting; PB: 1047 p.
- Country of Publication:
- United States
- Language:
- English
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