Transcript Clean Air Act 42 U.S.C. § 7401 et seq. (1970)

Clean Air Act
42 U.S.C. § 7401 et seq. (1970)
The Common Air Pollutants
(Criteria Air Pollutants)
•
•
•
•
•
•
•
Ozone
VOCs
Nitrogen Dioxide
Carbon Monoxide
Particulate Matter
Sulfur Dioxide
Lead
July 2002
Environmental Law
2
Ozone and VOCs
• Over the past 20 years national ambient
ozone levels decreased:
– 21 percent based on 1-hour data
– 10 percent based on 8-hour data.
– Between 1981 and 2000, emissions of VOCs
have decreased 32 percent. During that same
time period, emissions of NOx increased 4
percent.
July 2002
Environmental Law
3
Nitrogen Dioxide
• Between 1981 and 2001
– monitored levels of NO2 decreased 14 percent
– All areas of the country that once violated the
national air quality standard for NO2 now
meet that standard
– While levels around urban monitors dropped,
national emissions of nitrogen oxides
increased by 4 percent
• Causes primarily due to nitrogen oxides emissions
from diesel vehicles
July 2002
Environmental Law
4
Carbon Monoxide
• Between 1981 and 2000:
– Ambient average CO concentration dropped 61 %
– CO emissions levels decreased 18 %
• Between 1991 and 2000:
– Ambient CO concentrations decreased 41 percent
– Estimated number of exceedances of the national
standard decreased 95 percent
– while CO emissions fell 5 percent.
• This improvement occurred despite a 24 percent
increase in vehicle miles traveled in the United
States during this 10-year period.
July 2002
Environmental Law
5
Particulates
• Between 1991 and 2000, average PM10
concentrations decreased 19 percent, while
direct PM10 emissions decreased 6
percent.
July 2002
Environmental Law
6
Sulfur Dioxide
• Between 1981 and 2000:
– Average SO2 ambient concentrations decreased
50 percent
– Emissions of SO2 dropped 31 percent
• Between 1991–2000 :
– Ambient SO2 decreased 37 percent
– Emissions of SO2 dropped 24 percent
July 2002
Environmental Law
7
Air Pollution in Selected World
Cities 1995
TSP
SO2
NO2
50
80
100
Rio de Janeiro
139
129
NA
Mexico City
279
74
130
Beijing
377
90
122
Calcutta
375
49
34
Bangkok
223
11
23
Bucharest
July 2002
82
10
71
NAAQS
City
Environmental Law
8
1996 Toxic Air Pollutants (4.6M Tons)
Area/Other,
25%
On Road,
20%
Non Road,
30%
Major, 25%
July 2002
Environmental Law
9
Title I - Air Pollution Prevention
and Control
•Title I - Air Pollution Prevention and Control
•Part A - Air Quality and Emission Limitations
•Part B - Ozone Protection (replaced by Title VI)
•Part C - Prevention of Significant Deterioration of Air Quality
•Part D - Plan Requirements for Nonattainment Areas
July 2002
Environmental Law
10
Title II - Emission Standards for
Moving Sources
•Part A - Motor Vehicle Emission and
Fuel Standards
•Part B - Aircraft Emission Standards
•Part C - Clean Fuel Vehicles
July 2002
Environmental Law
11
•Title III - General
•Title IV - Acid Deposition Control
•Title V - Permits
•Title VI - Stratospheric Ozone Protection
July 2002
Environmental Law
12
Title I
Selected Sections of Part A —
Air Pollution Prevention and
Control
§107. Air Quality Control Regions
• State has authority to set air quality
control regions for primary and secondary
air quality control
• Contains a mechanism for reclassifying an
air quality control region as long as certain
conditions are met
• Includes ozone, carbon monoxide and
particulates, lead
July 2002
Environmental Law
14
§108. Air quality criteria and
control techniques
•
•
•
•
Specific Air Quality Criteria
Control Devices for Mobile Sources
Identifies Programs for Source Reduction
RACT/BACT/LAER Clearinghouse
July 2002
Environmental Law
15
§ 109. National ambient air quality
standards
• a national primary ambient air quality
standard and a national secondary ambient
air quality standard for each air pollutant
for which air quality criteria
• a thorough review of the § 108 criteria
every five years and the national ambient
air quality standards promulgated under
this section and revise the criteria based on
the review
July 2002
Environmental Law
16
§109 (cont.)
• Independent scientific review committee
composed of seven members including at
least one member of the National Academy
of Sciences, one physician, and one person
representing State air pollution control
agencies
July 2002
Environmental Law
17
§ 110. Implementation plans
• Each state shall develop a plan which
provides for implementation, maintenance,
and enforcement of such primary (and
secondary) standard in each air quality
control region (or portion thereof) within
such State
July 2002
Environmental Law
18
Title I
• § 111. Standards of performance for new
stationary sources
–
–
–
–
–
BACT for standard pollutants
Categories of Stationary Sources
Standards of Performance for new Sources
Enforcement Authority
Guides for State Plans
July 2002
Environmental Law
19
§ 112. National emission standards
for hazardous air pollutants
• Any Stationary Source ≥ 10 tons/yr any
hazardous air pollutant or ≥
25 tons/yr of any combination of hazardous air
pollutants
• List of Hazardous Air Pollutants and mechanism
to add to the list
• LAER
• Special Sections on Coke Ovens, Boat
Manufacture, POTWs
July 2002
Environmental Law
20
§ 112. National emission standards
for hazardous air pollutants
• System to assure compliance with new
construction
• Compliance schedule with existing sources
• Special Section on coke oven emissions
• Monitoring system to collect data on
ambient conditions
• National Strategy to reduce emissions
• State program authority
July 2002
Environmental Law
21
PORK
• (p) Mickey Leland Urban Air Toxics Research Center.(1) Establishment.- The Administrator shall oversee the
establishment of a National Urban Air Toxics Research
Center, to be located at a university, a hospital, or other
facility capable of undertaking and maintaining similar
research capabilities in the areas of epidemiology,
oncology, toxicology, pulmonary medicine, pathology,
and biostatistics. The center shall be known as the
Mickey Leland National Urban Air Toxics Research
Center. The geographic site of the National Urban Air
Toxics Research Center should be further directed to,
Harris County Texas, in order to take full advantage of
the well developed scientific community presence on-site
at the Texas Medical Center as well as the extensive data
previously compiled for the comprehensive monitoring
system currently in place.
July 2002
Environmental Law
22
1990 Amendment to §112
• A list of 100 substances that when accidentally
released are known to cause or may reasonably be
anticipated to cause death, injury, or serious
adverse effects to human health or the
environment
• The initial list shall include chlorine, anhydrous
ammonia, methyl chloride, ethylene oxide, vinyl
chloride, methyl isocyanate, hydrogen cyanide,
ammonia, hydrogen sulfide, toluene
diisocyanate, phosgene, bromine, anhydrous
hydrogen chloride, hydrogen fluoride, anhydrous
sulfur dioxide, and sulfur trioxide.
July 2002
Environmental Law
23
1990 Amendment to §112 (Cont.)
• Establishes the National Chemical Safety
Board
– To review chemical accidents and releases
– Establish procedures for reporting releases to
the National Chemical Safety Board
– Owners/Operators develop risk management
plans to detect and prepare response plans to
accidental releases
July 2002
Environmental Law
24
§ 114. Inspections, monitoring, and
entry
• Requires owners/operators to:
–
–
–
–
–
–
–
Establish and maintain records
Report
Monitor
Sample
Records of control equipment performance
Submit compliance certification
Allows government access to site and records
July 2002
Environmental Law
25
§ 118. Federal Compliance
• Requires all federal, state and local
governments to meet the same
requirements as private entities
• Exemption on §111 not allowed, §112 only
under specific conditions that are specified
• Government vehicles must meet inspection
and maintenance requirements
July 2002
Environmental Law
26
Title I
Part C - Prevention of Significant
Deterioration of Air Quality
(PSD)
Part C – Subpart 1 Clean Air
• §160. purpose/introduction
• §161. requires PSD plan
• §163. defines national parks covered by
PSD plan, sets ceilings for
specific
pollutants
• §164. Allows states to redesignate parks
into Class I with conditions
• §165. Permits and restrictions on
construction
July 2002
Environmental Law
28
Part C – Subpart 2 Visibility
Protection
• § 169a. Visibility protection for federal class I
areas
– Studies, selection of sites, control measures,
regulatory authority mainly directed toward:
• Power plants (determining best available retrofit
technology)
• Other stationary sources such as: coal cleaning plants
(thermal dryers), kraft pulp mills, Portland Cement
plants, primary zinc smelters, iron and steel mill plants,
primary aluminum ore reduction plants, primary copper
smelters, municipal incinerators, etc.
July 2002
Environmental Law
29
Part C – Subpart 2 Visibility
Protection
• §169b. Visibility
– Evaluate sources of visibility impairment and
Regions of impairment and provide clear
visibility in Class I regions
– Establish Visibility Transport
Regions/Commissions, which will:
• Study sources
• Make recommendations for control in transport
region for clean air corridors and restriction of new
construction
July 2002
Environmental Law
30
Title I
Part D - Plan Requirements for
Nonattainment Areas
Subpart I General Areas
§172. NONATTAINMENT PLAN
PROVISIONS IN GENERAL
• Areas designated under §107(d)
– Primary have 10 years to reach attainment
using techniques “as expeditiously as
practicable”
– Secondary must meet the standards “as
expeditiously as practicable”
• Must use RACT—Reasonably Available
Control Technology
July 2002
Environmental Law
32
Discussion Question
If the ozone in an area exceeds the control
level due to natural conditions, not
conditions induced by man, must the area
still meet the standard?
July 2002
Environmental Law
33
§173. Permits
• If a stationary source operates in a
nonattainment area, it may be required to
reach LAER—Lowest Available Emission
Rate
July 2002
Environmental Law
34
§174. Planning Procedures
• Specifies that the state must work with
adjacent states if areas overlap
• Provides a list of those who must be
involved in the process
• Sets dates by when the plan should be final
• Specifies approval process
July 2002
Environmental Law
35
§175(a) Maintenance
• If an area achieves attainment, the state
must develop a plan to maintain that status
for ten years
• The plan must be reviewed every eight
years
• Requirements for corrections
July 2002
Environmental Law
36
§176(a) Interstate Transport
Commissions
• When pollutants transport from one state
to another, allows Interstate Transport
Commissions by the EPA Administrator
July 2002
Environmental Law
37
§177. New Motor Vehicles
• In Nonattainment Areas allows stricter
standards for motor vehicles than the
national standard
• The California Standard is applied in
Nonattainment areas.
July 2002
Environmental Law
38
§179. Sanctions
• Can prevent state from receiving federal
funding for highway construction and
other transportation projects such as mass
transit.
July 2002
Environmental Law
39
Title I
Part D - Plan Requirements for
Nonattainment Areas SUBPART 2
- Additional Provisions for Ozone
Nonattainment Areas
§181. Attainment Dates for Ozone
Levels
Design Value
(ppm)
Primary
Standard
Marginal
0.121 ≤ 0.138
3 years
Moderate
0.138 ≤ 0.160
6 years
Serious
0.160 ≤ 0.180
9 years
Severe
0.180 ≤ 0.280
15 years
>0.280
20 years
Area Class
Extreme
July 2002
Environmental Law
41
§183. Federal Ozone Measures
• Control Technique Guidelines (CTGS) for
VOC sources within 3 years
• Compliance with CTGS 36 months after
issue
• Alternative Control Techniques
• Guidance for cost-effectiveness
• Defines BACT—Best Available Control
Technology
July 2002
Environmental Law
42
BACT
• The term "best available controls" means the
degree of emissions reduction that the
Administrator determines, on the basis of
technological and economic feasibility, health,
environmental, and energy impacts, is achievable
through the application of the most effective
equipment, measures, processes, methods,
systems or techniques, including chemical
reformulation, product or feedstock substitution,
repackaging, and directions for use,
consumption, storage, or disposal.
July 2002
Environmental Law
43
§183. Cont.
• Tank Vessel Standards
• Study to determine whether a design value
used by EPA is an appropriate predictor of
Ozone air quality.
July 2002
Environmental Law
44
§184. Control of Interstate Ozone
Pollution
• A single transport region for ozone (within
the meaning of section 176A(a)),
comprised of the States of Connecticut,
Delaware, Maine, Maryland,
Massachusetts, New Hampshire, New
Jersey, New York, Pennsylvania, Rhode
Island, Vermont, and the Consolidated
Metropolitan Statistical Area that includes
the District of Columbia, is hereby
established by operation of law.
July 2002
Environmental Law
45
§184. Control of Interstate Ozone
Pollution (Cont.)
• Allows additional control measures to be
required
July 2002
Environmental Law
46
Part D - Plan Requirements for
Nonattainment Areas
• SUBPART 3 - Additional Provisions for
carbon monoxide nonattainment areas
• SUBPART 4 - Additional Provisions for
particulate matter nonattainment areas
• SUBPART 5 - Additional provisions for
designated nonattainment for sulfur
oxides, nitrogen dioxide, or lead
July 2002
Environmental Law
47
TITLE II - EMISSION
STANDARDS FOR MOVING
SOURCES
National Emission Standards Act
Part A - Motor Vehicle Emission
and Fuel Standards
• §202. Establishment of standards
– standards applicable to the emission of any air
pollutant from any class or classes of new motor
vehicles or new motor vehicle engines, which in his
judgment cause, or contribute to, air pollution which
may reasonably be anticipated to endanger public
health or welfare
– Automobiles after 1983
– Heavy duty trucks and motorcycles after 1990
– Schedule for onboard vapor recovery
July 2002
Environmental Law
49
Part A - Motor Vehicle Emission
and Fuel Standards
• §206(a) Compliance Demonstration of:
– New motors
– New motors in operating cars with emission
control system
– Allows EPA to issue a certificate of
conformity for new cars and imports
– Can require testing by manufacturer
July 2002
Environmental Law
50
§ 207. Compliance by vehicles and
engines in actual use
• Sets emission standards for new:
– Cars
– Light trucks (< 6,000 gw tons)
– Trucks (> 6,000 gw tons)
• Sets compliance dates for each
July 2002
Environmental Law
51
§ 211. Regulation of fuels.
• Must furnish information on fuel or fuel
additives (including, but not limited to,
carcinogenic, teratogenic, or mutagenic effects
• Allows state to regulate fuel mixtures to obtain
standards in §110
• No diesel fuel with sulfur in excess of 0.05
percent (by weight) or which fails to meet
acetone index minimum
• Prohibits sale of gasoline with a Reid Vapor
Pressure in excess of 9.0 pounds per square inch
(psi) in high ozone season—ethanol enhanced
fuels allowed 10.0 psi provided conditions met
July 2002
Environmental Law
52
§ 211. Regulation of fuels (cont.)
• Reformulated gasoline
– Shall not exceed the NOx emission levels of
standard gasoline
– O2 levels of ≥ 2.0% by weight
– Benzene content ≤ 1.0% by volume
– No heavy metals including lead and
magnesium
– Aromatic concentration ≤ 25% volume
– During high O3, VOC emissions ≤ baseline
July 2002
Environmental Law
53
BASELINE GASOLINE FUEL
PROPERTIES
API Gravity . . . . . . . . . 57.4
Sulfur, ppm . . . . . . . . 339
Benzene, % . . . . . . . . . . .1.53
RVP, psi . . . . . . . . . . . . . 8.7
Octane, R+M/2 . . . . . . 87.3
IBP, F . . . . . . . . . . . . . . 91
July 2002
10% F . . . . . . . . . . . . . 128
50%, F . . . . . . . . . . . . . 218
90%, F . . . . . . . . . . . . . 330
End Point, F . . . . . . . . .415
Aromatics, % . . . . . . . . . 32.0
Olefins, % . . . . . . . . . . . . 9.2
Saturates, % . . . . . . . . . . 58.8
Environmental Law
54
§219. Urban Bus Standards
• Limits particulate emission from buses
manufactured after a certain date
• Requirement for retrofit of cleaner
emission technology in certain areas
July 2002
Environmental Law
55
Title II Part B - Aircraft Emission
Standards
• In place since 1970 and requires
compliance with air quality standards
July 2002
Environmental Law
56
Title II Part C - Clean Fuel Vehicles
• § 241. Definitions. Clean alternative fuel—any
fuel (including methanol, ethanol, or other
alcohols (including any mixture thereof
containing 85 percent or more by volume of such
alcohol with gasoline or other fuels),
reformulated gasoline, diesel, natural gas,
liquefied petroleum gas, and hydrogen) or power
source (including electricity) used in a clean-fuel
vehicle that complies with the standards and
requirements applicable to such vehicle under
this title when using such fuel or power source
July 2002
Environmental Law
57
Title II Part C - Clean Fuel Vehicles
§245. Standards
• Covered Fleet vehicles ≥ 10 vehicles
owned/operated by a single person
• Sets standards for fueling and emissions
from covered fleet vehicles ≥ 8,500 ≤
26,000 LBS
• Requires compliance with covered fleet
standards if the vehicles are operated in a
non-attainment area
July 2002
Environmental Law
58
TITLE III - GENERAL
• § 301. Gives Administrator authority to
write regulations and general directions
• §303. Give Administrator emergency
powers to assure protection of health or
environment
• § 304. Allows citizen suits under certain
conditions
• §306. Federal procurement prohibitions
July 2002
Environmental Law
59
TITLE III - GENERAL
• § 316. Withhold sewage treatment grants
if project does not comply with § 111
and/or 112
July 2002
Environmental Law
60
TITLE IV - ACID
DEPOSITION CONTROL
§ 403. SULFUR DIOXIDE ALLOWANCE
PROGRAM FOR EXISTING AND NEW UNITS
• (a) 1. Allocation of emissions for existing
sources and after 2001, cannot allow total
emissions ≥ 8.90 million tons SO2 from
utilities
• (b) allows allocation transfers
• (d) a system of tracking allocation transfers
• (e) new utility units may not emit more
than the units owned by the operator
July 2002
Environmental Law
62
§ 403 Phase I SO2 Requirements
• Lists each plant and its allocations
• Gives parameters for setting allocations
• Applicable until 2000
July 2002
Environmental Law
63
§405. PHASE II SO2
REQUIREMENTS
• Applicable after January 1, 2000
• Gives detailed instructions for setting
bonus points of SO2 emissions from
existing sources
• This system good until 2009
July 2002
Environmental Law
64
§407. NOx EMISSION
REDUCTION PROGRAM
• Establishes NOx emission standards for utility
boilers
– for tangentially fired boilers, 0.45 lb/mmBtu;
– for dry bottom wall-fired boilers (other than units
applying cell burner technology), 0.50 lb/mmBtu
• By 1997 EPA establishes standards for:
–
–
–
–
wet bottom wall-fired boilers
cyclones
units applying cell burner technology
all other types of utility boilers
July 2002
Environmental Law
65
§407. NOx EMISSION
REDUCTION PROGRAM (cont.)
• Revise NOx standards no later than 1993
under §111
• Additional requirements
July 2002
Environmental Law
66
§412. MONITORING, REPORTING, AND
RECORDKEEPING REQUIREMENTS
• Requires owners to install and operate
CEMS on each affected unit at the source
to quality assure the data for:
–
–
–
–
sulfur dioxide
nitrogen oxides
opacity
volumetric flow
• EPA will set up record-keeping protocols
July 2002
Environmental Law
67
TITLE V - PERMITS
TITLE VI - STRATOSPHERIC
OZONE PROTECTION
§602. LISTING OF CLASS I AND
CLASS II SUBSTANCES — Class I
• Group I
– chlorofluorocarbon-11
(CFC-11)
– chlorofluorocarbon-12
(CFC-12)
– chlorofluorocarbon-113
(CFC-113)
– chlorofluorocarbon-114
(CFC-114)
– chlorofluorocarbon-115
(CFC-115)
• Group II
– halon-1211
– halon-1301
– halon-2402
July 2002
• Group III
– chlorofluorocarbon-13 (CFC-13)
– chlorofluorocarbon-111 (CFC111)
– chlorofluorocarbon-112 (CFC112)
– chlorofluorocarbon-211 (CFC211)
– chlorofluorocarbon-212 (CFC212)
– chlorofluorocarbon-213 (CFC213)
– chlorofluorocarbon-214 (CFC214)
– chlorofluorocarbon-215 (CFC215)
– chlorofluorocarbon-216 (CFC216)
– chlorofluorocarbon-217 (CFC217)
Environmental
• Law
Group
IV
– carbon tetrachloride
70
§602. LISTING OF CLASS I AND
CLASS II SUBSTANCES — Class II
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
hydrochlorofluorocarbon-21 (HCFC-21)
hydrochlorofluorocarbon-22 (HCFC-22)
hydrochlorofluorocarbon-31 (HCFC-31)
hydrochlorofluorocarbon-121 (HCFC-121)
hydrochlorofluorocarbon-122 (HCFC-122)
hydrochlorofluorocarbon-123 (HCFC-123)
hydrochlorofluorocarbon-124 (HCFC-124)
hydrochlorofluorocarbon-131 (HCFC-131)
hydrochlorofluorocarbon-132 (HCFC-132)
hydrochlorofluorocarbon-133 (HCFC-133)
hydrochlorofluorocarbon-141 (HCFC-141)
hydrochlorofluorocarbon-142 (HCFC-142)
hydrochlorofluorocarbon-221 (HCFC-221)
hydrochlorofluorocarbon-222 (HCFC-222)
hydrochlorofluorocarbon-223 (HCFC-223)
hydrochlorofluorocarbon-224 (HCFC-224)
hydrochlorofluorocarbon-225 (HCFC-225)
July 2002
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
hydrochlorofluorocarbon-226 (HCFC-226)
hydrochlorofluorocarbon-231 (HCFC-231)
hydrochlorofluorocarbon-232 (HCFC-232)
hydrochlorofluorocarbon-233 (HCFC-233)
hydrochlorofluorocarbon-234 (HCFC-234)
hydrochlorofluorocarbon-235 (HCFC-235)
hydrochlorofluorocarbon-241 (HCFC-241)
hydrochlorofluorocarbon-242 (HCFC-242)
hydrochlorofluorocarbon-243 (HCFC-243)
hydrochlorofluorocarbon-244 (HCFC-244)
hydrochlorofluorocarbon-251 (HCFC-251)
hydrochlorofluorocarbon-252 (HCFC-252)
hydrochlorofluorocarbon-253 (HCFC-253)
hydrochlorofluorocarbon-261 (HCFC-261)
hydrochlorofluorocarbon-262 (HCFC-262)
hydrochlorofluorocarbon-271 (HCFC-271)
Environmental Law
71
§ 603. MONITORING AND
REPORTING REQUIREMENTS
• Directs EPA to set up monitoring and reporting
requirements for Class I and Class II materials
• Covers manufacture and import of these materials
• Requires NOAA to report on tropospheric concentration
of chlorine and bromine and on the level of stratospheric
ozone depletion every three years with update
projections of:
– peak chlorine loading
– rate at which the atmospheric abundance of chlorine is projected
to decrease after the year 2000
– date by which the atmospheric abundance of chlorine is projected
to return to a level of two parts per billion.
July 2002
Environmental Law
72
§604. PHASE-OUT OF PRODUCTION AND
CONSUMPTION OF CLASS I SUBSTANCES
• Sets production phase out table for Class I
substances from 1991-2001
• Allows limited production to developing
countries that are signatory to the
Montreal Protocol until 2001 and with
methyl chloroform until 2012
• Allows limited production for National
Defense and for specific fire suppression
July 2002
Environmental Law
73
§605. Phase out of Class II
Substances
• Restriction of Use of Class II Substances.Effective January 1, 2015, it shall be unlawful for
any person to introduce into interstate commerce
or use any class II substance unless such
substance- (1) has been used, recovered, and
recycled; (2) is used and entirely consumed
(except for trace quantities) in the production of
other chemicals; or (3) is used as a refrigerant in
appliances manufactured prior to January 1, 2020
July 2002
Environmental Law
74
§606. Accelerated Schedule
• Administrator may accelerate the phase
out schedule if he thinks it is necessary to
protect health and the environment
July 2002
Environmental Law
75
§608. NATIONAL RECYCLING AND
EMISSION REDUCTION PROGRAM
• Authorizes EPA to establish requirements for recycling
these materials
– The regulations under this subsection shall include requirements
that• (A) reduce the use and emission of such substances to the lowest
achievable level, and
• (B) maximize the recapture and recycling of such substances.
– Effective July 1, 1992, it shall be unlawful for any person, in the
course of maintaining, servicing, repairing, or disposing of an
appliance or industrial process refrigeration, to knowingly vent
or otherwise knowingly release or dispose of any class I or class
II substance used as a refrigerant in such appliance (or industrial
process refrigeration) in a manner which permits such substance
to enter the environment
July 2002
Environmental Law
76