"Wasting Away the Treasure Chest: EPA's Definition of Solid Waste and How It Could Impact Alternative Fuel Use"

Two HGS attorneys recently co-authored an article in Cement Americas (October 2011), regarding (EPA's) new rule defining solid waste for purpose of air regulations. Once the Commercial or Industrial Solid Waste Incinerator (CISWI) rule becomes effective and a compliance deadline established, cement kiln operators will need to quickly determine whether any alternative fuels or ingredients being used constitute solid waste. While EPA appreciates that guidance is needed for implementation of the NHSM rule, it is highly likely that uncertainties will remain associated with these determinations. This uncertainty stymies businesses that are unsure of what regulations apply and how to prepare for the cost of the regulations. This uncertainty ultimately leads to reduced usage of alternative fuels. The firm has several attorneys who regularly represent clients in this field, and has more than thirty years of experience with solid waste and air regulation. If you are interested in finding more information, please contact Angela Morrison or Carl Eldred.