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In this review, a source located in a "clean air" area must demonstrate that its emissions will not consume more than the available "increment" of pollution allowed in that area. A source in a so-called nonattainment area must obtain greater than one-for-one offsets for any increased emissions attributable to that source. Prior to joining the firm, he was Senior Attorney at the Natural Resources Defense Council, which he cofounded in 1970. Parker is an associate with O'Melveny & Myers specializing in the practice of environmental law. From 1975 to 1991, he was also cofounder and chairman of the National Clean Air Coalition, where he led successful efforts to reshape the federal Clean Air Act in 19. He earned his law degree from Yale University in 1985. EPA, DRAFT REVISED INTERPRETATIVE RULING 6 (June 20, 1990) (EPA Docket No. This Article provides a glimpse into the regulatory machinery needed to deal with implementing just one aspect of the Clean Air Act Amendments of 1990: whether an electric utility's proposed renovations at one of its facilities constitutes a "modification" triggering new source performance standards and new source review programs.

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Implicit in this focus on new and modified plants is the expectation that local air quality goals are sufficiently rigorous and that they will become easier to attain as new, or modified, clean plants replace old, more polluting, plants.

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