I was very disappointed in your article concerning enforcement of the Clean Air Act and the new New Source Review (NSR) provisions (ENR 11/17 p. 12). It is clear that the authors did not read the new provisions but relied upon claims of those who oppose them. The truth is that the new provisions are not a reversal of the Clean Air Act. Rather, the new rule simply defines routine maintenance, repair and replacement (RMRR).
It is important to note that the original objective of the NSR in the 1977 Clean Air Act was to be a preconstruction permitting program with two primary purposes: ensuring maintenance of air-quality standards when factories, industrial boilers and powerplants are modified or added; and assuring that state-of-the- art control technology is installed in new plants or in existing plants when undergoing major modifications.