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U.S. EPA Finalizes Disapproval of Environmental Stewardship Program Incentives


By Andy Bowman, Attorney, Bingham Greenebaum Doll LLP

U.S. EPA has taken final action to disapprove the use of three incentives that IDEM had sought to provide to participants in IDEM’s Environmental Stewardship Program (ESP). See 75 Federal Register 72964 (November 29, 2010). The three incentives disallowed by U.S. EPA include: (1) providing ESP participants the same incentives offered to participants in U.S. EPA’s former National Environmental Performance Track Program; (2) monthly averaging of VOC coating limits; and (3) relaxed permitting of pollution prevention projects. U.S. EPA’s disapproval of these incentives becomes effective on December 29, 2010.


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