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air quality

  • Obtaining variances so that production can continue in the face   of unexpected failure of environmental compliance, without fear of fines or   penalties. (Requires as much mitigation of environmental harm and positive   environmental steps as possible, but can provide dispensations for continued   operation for up to several years.) See "Update: Resolving Air Quality Issues".


  • Negotiating a resolution that allowed an oil company to ship its   oil by truck when a major pipeline became blocked. The company lacked a   permit for truck shipping, yet by swift action in applying for a permit was   granted a temporary permit while the application was processed by the air district.


  • Obtaining emergency variances (within 24 hours of an equipment   breakdown that resulted in temporary non-compliance) so that operations could   continue, meet deadlines and avoid severe market loss.


  • Negotiating Notices of Violation, with very large potential   penalties under California Health & Safety Code Section 42402 et seq.,   down to manageable penalties, sometimes based in part on improved operating   practices and training, which help avoid future problems and reduce current   penalties even further.


  • Representing the members of a major trade association in   negotiation with air quality staff during development of rules, so that these   association members can comply with the rules, more easily, with better   environmental results, and more economically.


  • Negotiating a way for a manufacturer to continue use of a   non-complying adhesive, critical in the making of public safety equipment,   until that manufacturer could develop an effective alternative adhesive.


  • Negotiating a way for a high-quality printing operation to meet   its "do-or-die" printing contracts, while operating in   non-compliance, yet minimizing any negative environmental effects.


  • Bridging the gap, by a variance or negotiated settlement, where   air agency delay in issuing permits causes the client to miss a compliance   deadline.


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