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Air Guide 10: Federal Enforceability of Information on Air Operating Permits
The USEPA described the criteria for "federally enforceable" state operating permit programs in amendments to 40 CFR Parts 51 and 52, 54 FR 27274. The purpose of this document is to outline the procedural requirements and permit conditions to be followed by permit writers to ensure that limitations set forth in an air operating permit will be "federally enforceable." This guidance will be modified pending the adoption of revisions to 6 NYCRR Part 201 which are being made in accordance with requirements set forth in Title V of the Clean Air Act Amendments of 1990 (CAAA) and the corresponding regulation defining the elements of a Title V permit as listed in 40 CFR Part 70.
Table of Contents
- General Criteria
- Specific Requirements for Developing Permit limitations
- Procedural Requirements
Table 1 - Permitting Responsibilities
Model Public Notices
Attachment A - Existing Source
Attachment B - New Source/Modification
Attachment C - Emission Reduction Credit Certification for Past reductions
Attachment D - Emission Reduction Credit Certification for Future reductions
Attachment E - Illustrative Examples
The "potential to emit" of a stationary source is a critical factor in establishing applicability and compliance with air emission regulations. According to both state and federal Statutes the potential to emit is defined as the maximum capacity of a facility or source to emit any air contaminant under its physical and operational design. Any physical or operational Limitation on the capacity of the facility or source to emit any air contaminant, including air pollution control equipment and/or Restrictions on the hours of operation, or on the type or amount of material combusted, stored, or processed, shall be treated as part of the design only if the limitation is federally enforceable by the Commissioner and the Administrator (of the USEPA).
In many previous circumstances, the potential to emit has been Limited by permit conditions either to maintain compliance with applicable rules or to keep new sources or modifications under the thresholds for PSD or Part 231 (nonattainment review) applicability. With the passage of the CAAA, source owners will now have to comply with an ever greater number of complex regulatory requirements. This translates into a significant increase in workload for both the regulatory agency and the source owner. For example, based on maximum capacity, there currently exists within new York State, a potential of 30,000 sources subject to Reasonably available Control Technology (RACT) for VOC and NOx and 11,000 sources subject to Title V. In addition, numerous other sources will likely be subject to federal New Source Review (NSR) requirements specified in 6 NYCRR Part 231 which could involve implementing such onerous measures as Lowest Achievable Emission rate (LAER) as well as emission offsets. Sources may also seek to establish emission reduction credits for the purpose of creating tradable offsets under the same provisions which would otherwise require processing as individual revisions to the State implementation Plan (SIP). It is the goal of the Department to address this workload by using permit conditions to limit or "cap" the potential to emit to below various applicability thresholds of those sources which qualify. These are sources which, based on their maximum actual operations, should not be applicable. By doing so, needless permit processing and review will be avoided while allowing otherwise limited resources to be Concentrated on truly applicable sources.
In order to ensure that such limitations and reductions are Actually incorporated into a source's design and followed in practice, the USEPA has reiterated through its policy directives that federal enforceability of permit limitations is necessary; otherwise Clean Air Act requirements still apply. If properly written, the "federally enforceable" permit will allow a regulatory agency's field inspector to enter a facility and determine the compliance status by reviewing the permit and its conditions, and any record keeping, reporting, or other monitoring data that is required by the air operating permit.
The concept of federal enforceability also requires that an opportunity for public notice and participation be provided prior to the issuance of any air permits imposing limitations on a source's operation. This will allow interested parties the chance to review the record to determine whether a proposed limitation or reduction will produce the benefits claimed, whether the applicant is seriously committed to the limitation, and whether practical means exist to monitor compliance with the limitation.
If the procedures in this Air Guide are followed, a source will Receive a federally enforceable limitation on its potential to emit. Violation of such a limitation could result in an enforcement action not only by the Department, but also by the USEPA, pursuant to Sections 113 and 167 of the Clean Air Act and by citizens, pursuant to Section 304 of the Act.
Finally, with the adoption of this air guide it should be noted that any specific guidance regarding limiting the potential to emit of a source and associated noticing and permit processing requirements found in previous air guides (i.e., Air Guide 12) will be superceded.
- General Criteria
The term "federally enforceable" refers to all Limitations and conditions which are enforceable by the administrator of the USEPA, including:
- requirements developed pursuant to any new source performance standards (NSPS) as listed in 40 CFR 60 or national emission standards for hazardous air pollutants (NESHAPS) as listed in 40 CFR 61,
- requirements within any applicable federally-approved state implementation plan (SIP), and
- any requirements contained in a permit issued pursuant to federal PSD regulations (40 CFR 52), or pursuant to PSD or operating permit provisions in a SIP which has been federally approved in accordance with 40 CFR 51 Subpart I.
Pursuant to 40 CFR Parts 51 and 52, terms and conditions contained in New York State operating permits are considered federally-enforceable because the following conditions have been Met:
- the state's operating permit program is approved by the USEPA and incorporated into the applicable SIP under section 110 of the Clean Air Act (Part 201 is approved at 40 CFR 52.1679);
- the operating permits are legally binding on the source under the SIP and the SIP specifically provides that permits that are not legally binding may be deemed not "federally enforceable" (see 40 CFR 52.1679);
- all emissions limitations, controls, and other requirements imposed by such permits are no less stringent than any corresponding federal or SIP standards and requirements (see 6 NYCRR § 201.4(3));
- the limitations, controls and requirements in the operating permits are permanent, quantifiable, and otherwise enforceable as a practical matter as set forth in this air guide; and
- the permits are issued subject to public participation, timely notice and opportunity for public comment in accordance with 6 NYCRR § 621.6, as required under Section C of this Air Guide.
In conformance with the above conditions, the NYSDEC is proposing to submit this guidance as a revision to its SIP, which will bind the Department to follow these procedures in issuing federally enforceable permits.
- Specific Requirements for Developing Permit Limitations
Permit limitations are the most direct way for a source to restrict its potential to emit. Developing appropriate (i.e., federally enforceable) permit conditions requires that the permit reviewer be cognizant of:
- what types of permit limitations legally limit the potential to emit of a source;
- whether the time periods used for limiting production and operation are enforceable as a practical matter; and
- whether permit limitations proposed by a source to limit the potential to emit below applicability threshold levels are being used as a means to circumvent certain preconstruction review requirements (i.e., false or deceptive permits).
- Types of Permit Limitations
There are three general categories of permit limitations:
Production limits which restrict the amount of final product which can be manufactured or otherwise produced at a source,
Operational limits which encompass all other restrictions on the manner in which a source functions, and
Emission limits which restrict the amount of a pollutant emitted from a source over a set time period.
Typical examples of production and operational limitations include:
- requirements to install and operate air pollution control equipment at prescribed efficiencies;
- restrictions on design capacity utilization (i.e., limiting the ability of a source to operate at its design capacity)
- restrictions on hours of operation; and
- restrictions on the types or amount of material processed, combusted or stored.
If a permit does not contain any limits on the capacity utilization or hours of operation, the potential to emit must be calculated assuming operation at maximum capacity and continuous operation (8760 hours per year). Emission limitations that do not represent the emission rate potential (i.e., the maximum emissions of a source operating at full design capacity without pollution controls) must include production and/or operational limitations for purposes of practical enforcement. Any production and/or operation limits must be stated as conditions that could be enforced independently of one another so that if one of the conditions is found to be difficult to monitor for any reason, the other may still be enforced. As an example, fuel restrictions might include independent conditions on both the type and amount of fuel combusted.
Production and operational limits should also have record keeping requirements that allow verification of a source's compliance with its limits. For example, permits with limits on hours of operation or amount of final product should require that an operating log containing the hours of operation or the amount of final product produced be maintained and made available to the field inspector upon request.
Permits that require the installation of air pollution controls having a specified control efficiency should also have conditions listing the operating parameters under which the control efficiency was achieved in order for the permit to be practically enforceable. For example, a particulate source requiring 95% emission controls may opt to install a baghouse by a manufacturer claiming a 95% control efficiency for the type of source in question. In this case, the manufacturer should provide the source owner with sufficient documentation to support the assertion. This information should then be included with any permit application. Once this has been verified by the permit reviewer, the permit conditions should specify that the baghouse must maintain certain key operating parameters as documented during the time of greatest efficiency. The parameters might include such items as air to cloth ratio, inlet and/or outlet temperature, pressure drop, fabric filter material type, etc. By noting operation within the specified parameters, the field inspector can then assume that the control Device is functioning properly and achieving the appropriate efficiencies.
In some instances, the permit reviewer may require an emission test of the source to verify the control efficiency. If the operating parameters are modified as a result of the test, the permit conditions should be revised accordingly assuming that the required control efficiency had been achieved during the test.
While the use of blanket emission limits to restrict potential To emit is generally prohibited because of the inability to practically enforce those limits, certain situations do allow their application. For example, federally enforceable permit conditions containing short term emission limits (i.e., lbs/hr) may be used to restrict the potential to emit provided that the limits reflect the operation of the control equipment, and the conditions include requirements to install, maintain, and operate a continuous emission monitoring system (CEM) system, retain the CEM data and specify that the CEM data is to be used to determine compliance with the emission limit.
Emission limits may also be employed for permits involving VOC surface coating operations that do not have add-on emission controls but instead emissions are restricted through limiting VOC content and quantities used. If it is determined that imposing such restrictions is impractical because of the multiplicity of coatings used or the otherwise variable nature of the operation, emission Limits may be employed provided they are combined with a requirement to calculate daily emissions. In this case, the source would be required to maintain the necessary records for calculating the emissions, including daily quantities and the VOC content of each coating used. Application of emission limits in this instance would be more easily enforceable than operating or production limits.
- Acceptable Time Periods for Limiting Production and Operation
For purposes of issuing "federally enforceable" permits, the NYSDEC is following the USEPA policy that the time period over which production and operational restrictions extend should be as short as possible and should be generally limited to one month. The theory behind this policy is that enforcement actions can be initiated for continuing violations without waiting an excessive amount of time.
If a one month limit is not reasonable, a limit spanning a longer time is appropriate provided it is a rolling limit. However, the limit should not exceed an annual limit rolled on a monthly basis. As an example, an oil-fired boiler might be limited to burning a total quantity of 840,000 gallons of residual (#6) fuel oil (roughly corresponding to 100 tpy of SO2 emissions) over any consecutive 12 month period. This would then be verified by monthly fuel use records.
Permits where longer rolling limits are used to restrict production should only be issued to sources with substantial and unpredictable annual variation in production (i.e., peaking turbines, emergency boilers). Rolling limits may also be utilized for sources subject to seasonal operations. For example, an asphalt plant that is typically shut down between November and April each year, may have permit conditions containing a zero operation limit for those months and an appropriate hourly operation limit for every other month within the paving season. Under no circumstances, would a production or operation limit expressed on a calendar year annual basis be considered a legally enforceable restriction.
- Deceptive Operational Limits
The definition of potential to emit allows sources to avoid applicability to various rules by limiting emissions through federally enforceable permit limitations. However, federal enforceability also requires that such limitations be permanent and implies that they conform with the actual design and intended operation of the specific project. Permits with conditions that do not reflect a source's planned mode of operation are not considered valid and may not shield a source from the preconstruction review requirements associated with PSD and Part 231 nonattainment (NSR) permits. Sources which attempt to expedite construction by securing minor source status through the receipt of operational restrictions from which the source intends to free itself shortly after operation are to be treated as circumvention of preconstruction review requirements. In such cases, the resultant permit limits cannot be used in the Determination of potential to emit.
According to 40 CFR §52.21(r)4, when a source that is minor as a result of operating restrictions imposed in a construction permit later applies for a relaxation of that construction permit which would make the source major, PSD requirements shall apply to the source or modification as though construction had not yet Commenced on the source or modification. The source would be subject to retroactive BACT and other PSD requirements. (Note: For sources located in nonattainment areas, corresponding LAER and other NSR requirements would apply.) In addition, an enforcement action may also be initiated if the original minor source Construction permit was considered false or deceptive. For cases where a source legitimately changes a project after finding that the operational restrictions which were taken in good faith cannot be complied with, enforcement action could be avoided provided the available evidence in the case supports the source's claim of good faith intentions.
An example of a situation which might be scrutinized for deceptive operational limits involves the construction of a manufacturing facility such as a glass processing plant in a PM-10 attainment area with a physical capacity significantly greater than the limits specified in a permit condition. At maximum design capacity the facility generates 140 tpy of PM-10 emissions. The facility however applies for and receives a permit with federally enforceable conditions which limit the PM-10 emissions to 90 tpy thus keeping the source below the PSD applicability threshold of 100 tpy for this type of source. One year later, the source applies for a modification which will increase PM-10 emissions by 12 tpy. The increase due to the modification is less than the PSD significant net emissions increase threshold for PM-10 emissions (i.e., 15 tpy) consequently PSD applicability is avoided again. If the application is accepted as is and the subsequent permit modification is issued, the facility has in effect gained an operating permit for a PSD major facility within a year without undergoing preconstruction review requirements. This type of project segmentation is specifically prohibited under 40 CFR §52.21(r)4. The facility would need to undergo retroactive PSD preconstruction review requirements. If it was determined that the facility purposely planned to circumvent PSD requirements an enforcement action would also need to be initiated.
Scenarios such as the one described above point out the necessity of assessing proposed permit limitations for suitability to a project on a routine basis. Exposing a deceptive permit application involves an evaluation of specific facts and evidence for each individual case. Listed below are potential (though not always available) sources of evidence that may be considered in determining whether a minor source construction air permit is false or deceptive:
- Filing a PSD or nonattainment NSR permit application
strong evidence of an intent to circumvent major source preconstruction review occurs if a major source or major modification permit application is filed simultaneously with or at approximately the same time as the minor source construction permit or even after the minor source has commenced operation.
- Applications for funding
applications for funding, such as public utility bond issues or commercial loans, may be checked for a certain guaranteed level of operation which is higher than that provided in the construction permit. If the project would not be funded or if it would not be economically viable if operated on an extended basis (> 1 year) at the permitted level production, this might be considered as evidence of circumvention.
- Reports regarding projected production levels
stockholder reports, business permit applications, etc. can be checked for evidence of circumvention by reviewing projected operation or production levels necessary to meet consumer demands. If the levels listed in the permit are lower, this can also be construed as evidence of circumvention.
- Statements by authorized representatives regarding operating plans
source representatives may make statements to the USEPA, state or local permitting agencies concerning operating plans which may in turn provide evidence of an intent to circumvent preconstruction review requirements
It should be noted that if a determination is made that a permit contains false conditions for one pollutant resulting in that project or source being designated a major source or major modification, the permit may possibly still contain valid limits on the potential to emit for other pollutants. In such cases, the entire source must still go through new source review. For PSD review, this would require all pollutants for which there is A significant net increase to undergo a Best Available Control Technology (BACT) analysis. For nonattainment new source review, LAER determinations would be required only for those pollutants for which the source is major. However, for major modifications, LAER Determinations would be required for all nonattainment pollutants emitted in significant amounts. If still valid limits in a Partially void minor source construction permit keep certain pollutants below significance levels, then those pollutants do not require a BACT or LAER analysis. Conversely, if a source or modification is determined to be major for PSD or nonattainment new source review because a portion of its minor permit is voided, a BACT or LAER analysis (whichever is applicable) would be required for all significant pollutants.
As with any permit change, if a source seeks to obtain a greater operational flexibility than that allowed in its permit, it would need to apply for the modification of the permit which would in turn require a reevaluation of the sources applicability and potential impacts.
- Filing a PSD or nonattainment NSR permit application
- Types of Permit Limitations
- Procedural Requirements
All federally enforceable air operating permits are issued subject to public participation requirements. This means that a timely notice of the draft permit and the issuance of the final permit will be provided to the public and the USEPA by the Department. In addition, the USEPA will be provided with a copy of each proposed (or draft) and final permit intended to be federally enforceable.
Permit application administrative procedures which satisfy Uniform Procedures Act (UPA) and federal public participation requirements are as follows:
Facilities seeking to limit their emissions, must submit an application for modification of the certificate to operate for each emission source requiring an emission potential limitation. Total facility emissions for affected categories of emissions must be below applicable thresholds to satisfy capping requirements.
The source owner shall submit capping requests and accompanying application(s) to the Division of Regulatory Affair's (DRA) Regional Permit Administrator responsible for the Region in which the facility is located. Forms prescribed by the Department shall be utilized (for the present, existing application forms are to be used, ultimately the new application form under development will be used).
The application shall be logged on the Regulatory Compliance information System (RCIS) as a permit modification and shall be treated as a new application for permit per 6 NYCRR § 621.13 (e) (3) (opportunity for public comment and/or hearing required). As a UPA minor project 15 days is provided for determining completeness which includes the Department's preparation of a draft permit. A decision on granting the modification is due within 45 days of completeness. UPA time frame waivers or extensions may be requested as necessary to complete reviews.
If, however, the permit application or modification request involving the cap is intended to restrict a proposed new emission source or modification to an existing facility or the potential to emit of a new facility from being subject to New Source Review under Part 231 or PSD, it will be treated as a major project and subject to appropriate procedures and time frames (60 days for completeness determination, notice of complete application and Draft permit in the Environmental Notice Bulletin (ENB) and Newspaper, 90 days from completeness to issue with opportunity for a hearing). This will be necessary to satisfy Title V permitting requirements as well as to provide reasonable public notice of potentially major emitting facilities which will be restricted with permit limits.
The application shall be forwarded to the Regional Air Pollution Control Engineer (RAPCE), the Multi-media Pollution Prevention (M2P2) Facility Manager, and other appropriate Department personnel, for review. The RAPCE is responsible for determining acceptability of the application and preparation of a draft permit containing emission limits and appropriate monitoring and/or record keeping conditions. Technical review will focus on verifying revised emission estimates and the proposed method of compliance. DRA will follow normal notification procedures for incomplete applications.
State Environmental Quality Review Act (SEQR) Status: Capping of Existing permitted emission sources will be Type II actions as they represent an additional restriction of emissions for which a SEQR Determination has already been made. Applications involving new or modified sources will generally qualify as unlisted actions under 6 NYCRR Part 617.
DRA will prepare a public notice and make arrangement for publication in the ENB. A standard notice format is presented in attachment A. All notices shall be "Notices of Complete Application for Permit Modification," and provide for a 30 day comment period. As stated earlier, the public notice must also be published in a newspaper if the cap is required to prevent a proposed new source or modification from being subject to 6 NYCRR part 231 or PSD. A second standard notice format is presented in attachment B for this application of an emissions cap.
Sources seeking to establish emission reduction credits for the purpose of creating emission offsets or to facilitate emissions trading are required to meet all federal enforceability criteria according to the CAAA, NY state Clean Air Compliance Act and 6 NYCRR Part 231. Procedural requirements are similar to those outlined in the previous paragraph except that the standard notice formats found in attachments C and D should be followed.
DRA shall distribute the notice of complete application and draft permit to:
The applicant
USEPA, Region II Office
Air Compliance Branch
26 Federal Plaza
New York, NY 10278
M2P2 Facility Manager
Other Department Reviewers
DRA will receive comments and evaluate their content with the RAPCE and other programs as appropriate. DRA will reply to comments, based on responses provided from the RAPCE and other programs, and when necessary prepare requests for hearing.
Permit issuance will be undertaken by the Regional Permit Administrator who will distribute copies to:
The RAPCE
M2P2 Facility Manager
Other Department Reviewers
Interested Parties
The RAPCE shall provide notification to the Division of Air Resources Central Office of those facilities which have capped their emissions, using the attached Source Management System or SMS Facility Status Form. Central Office shall update computer Records by adding the appropriate codes to indicate a facility has been capped. Regional air staff will maintain responsibility for adding special conditions to the SMS records in order to show how the facility is being capped and how capping will be monitored and verified. When the Air Facility System (AFS) computer data program is implemented the regional Air Resources staff will edit computer Files to reflect changes in permit limits and conditions as part of the permit modification. A chart defining responsibilities is provided in Table 1.
Approved _________________________
Tom Allen, Director, Division of Air Resources
Approved _________________________
Lou Concra, Director, Division of Regulatory Affairs
Table 1
Permitting Responsibilities for Establishing Federally Enforceable Permits
Division of Regulatory Affairs
- Receive and distribute permit application to technical staff for Review
- Evaluate application using input from technical staff
- Prepare all notices
- Arrange for publication of notices
- Receive and reply to public comments
- Prepare for hearing, if necessary
- Issue and distribute permit to appropriate parties including applicant, USEPA, RAPCE, M2P2 coordinator, etc.
Division of Air Resources
- Determine acceptability of application including verification of emission estimates and compliance methods
- Prepare draft permit with emission limits and compliance monitoring provisions
- Provide notification to Central Office Air staff of permit limits or "cap" via Source Management System (SMS) Facility Status Form
- Update system statewide registry of capped sources
(Central Office Air Staff)
Update SMS records (i.e., add special conditions indicating how source is being limited or "capped" and how limitations will be monitored and verified)
Attachment A Model Public Notice (Existing Source)
The Department has received (an) application(s) from [owner's/company name] for (a) modification(s) to (an) existing air pollution control permit(s) for [list brief description of source(s), i.e., combustion units, incinerators, processes...] discharging to emission points [list emission point ID #'s] located at [list facility name, street location, town, county].
These/This modification(s) is/are being proposed by the applicant for the purpose of restricting the potential to emit of these emission sources through enforceable permit conditions which will limit or cap emissions at a level which is below the [list the applicability threshold in tpy] applicability threshold for [list the appropriate regulation, i.e., RACT, PSD, Part 231, facility permit (Title V), MACT,...]. By accepting these state and federally enforceable limits, the source/facility will not be subject to this particular regulation.
The applicant has agreed to permit conditions which will limit emissions of [list applicable contaminants] to [___ tpy (list Contaminant(s), either NOx, VOC, CO, PM-10 or SO2)] through restrictions on [describe method of restricting emissions, i.e., limiting hours of operation, fuel usage, production/throughput,...]. The permittee will be required to maintain records and report this data to verify compliance with permit conditions and limits. The application [list application iD #] is available for review at the Region___ office. Contact person is:[list contact person name, address and phone #]. Comments will be received for 30 days from the date of this notice.
Attachment B
Model Public Notice (New Source/Modification)
The department has received (an) application(s) from [owner's name/company] for [list the quantity of] air pollution control permits to construct and operate (new/modified) [describe sources, i.e. stationary combustion, industrial process, incinerator] at [facility name, street location, town, county]. The project involves [further description - optional].
The applicant has proposed to accept a cap on emissions of [name triggering contaminant(s)] which will restrict the potential to emit of this/these source(s) to a level which is below the applicability threshold for [cite regulation, i.e., PSD, Part 231] which is [list annual tonnage threshold]. By accepting these state and federally enforceable limits the [name of the project, facility] will not be subject to these regulations.
The applicant has agreed to permit conditions which will limit emissions of [list applicable contaminants] to [___tpy (list Contaminant(s) either NOx, VOC, CO, PM-10 or SO2)] through restrictions on [describe method of restricting emissions, i.e., limiting hours of operation, fuel usage, production/throughput,...]. The permittee will be required to maintain records and report this data to verify compliance with permit conditions and limits. The application [list application iD #] is available for review at the Region___ office. Contact person is:[list contact person name, address and phone #]. Comments will be received for 30 days from the date of this notice.
Attachment C
Model Public Notice (Emission Reduction Credit Certification for Past Reductions)
The Department has received (an) application(s) from [owner's name] for (a) modification(s) to (an) existing air pollution control permit(s) for [brief description of source(s), i.e., combustion units, process units, incinerators] located at [list facility name/company, street location, town, county]. These/This modification(s) is/are being proposed by the applicant for the purpose of establishing certified emission reduction credits for past reductions which were the result of [shutdown, curtailment, voluntary emission controls, source reduction, etc.] of an/some emission source(s) at this facility.
The [owner name/company] will be establishing emission reduction credits of [___ tpy (list contaminant(s), either NOx, VOC, CO, or PM-10)] in accordance with 6 NYCRR Part 231 "New Source Review in Nonattainment Areas" with these/this permit modification(s). The application [list application ID #] is available for review at the Region ___ office. Contact person is [list contact person name, address, and phone #]. Comments will be received for 30 days from the date of this notice.
Attachment D
Model Public Notice
(Emission Reduction Credit Certification for Future Reductions)
The Department has received (an) application(s) from [owner's/company name] for (a) modification(s) to (an) existing air pollution control permit(s) for [brief description of source(s) i.e.,combustion units, process units, incinerators, etc.] located at [facility name, street location, town, county]. These/This modification(s) is/are being proposed by the applicant for the purpose of establishing certified emission reduction credits which will be transferred to and used in support of a [proposed major facility or proposed source project] at [name of user of emission reduction credit, facility name, location]. The emission reduction which is scheduled to occur on [proposed date] will be the result of [shutdown, curtailment, voluntary control, source reduction, etc.] of an/a number of emission sources at [name of applicant's facility, location].
The applicant will be establishing emission reduction credits of [___ tpy (list contaminant(s) either NOx, VOC, CO, or PM-10)] in accordance with 6 NYCRR Part 231 "New Source review in nonattainment Areas" with these/this permit modification(s) which will become effective on the date specified above. The reductions must physically occur prior to commencement of operation of the [proposed facility/source project] at [user facility name].
The application [list application ID #] is available for review at the Region___ office. Contact person is [name, address, phone #]. Comments will be received for 30 days from the date of this notice.
Attachment E
Illustrative Examples
Listed below are various hypothetical situations used to illustrate the type of permit restrictions which may or may not be federally enforceable.
- Requirements to Install and Operate Air Pollution Control Equipment at Prescribed Efficiencies (and Establishing Enforceable Emission Limitations)
Example #1 - A plant consisting solely of A small rock crusher has the following permit restrictions: .05 gr/dscf; fabric filter to be employed and maintained at 99% efficiency.
Assuming that maintaining the fabric filter at 99% efficiency will result in emissions less than some desired threshold (e.g. 250 tpy for PSD applicability), this permit would limit potential to emit if it also contained either parameters that allow the Department to verify the fabric filter's operating efficiency or a requirement to install and operate continuous opacity monitors together with a specification that the monitoring data be used to verify compliance with emission limits. If the second alternative were to be adopted, it would not be necessary to require that the fabric filter be maintained at 99% efficiency.
To determine potential to emit, the efficiency rate of the fabric filter would be multiplied by the maximum uncontrolled emission rate, the maximum number of operating hours and maximum throughput capacity since no operating or production limits are present. The efficiency rate of the fabric filter would not be enforceable as a practical matter unless there were an enforceable means to monitor the fabric filter performance on a short term basis. The two alternatives discussed above would satisfy this requirement.
Example #2 - A small wood furniture line located in upstate NY has the capability of utilizing 10,000 gallon of coating/month, with the following permit restrictions: 3.0 lb VOC/gallon of coating minus water; 4 tons VOC/month; monthly VOC emissions to be determined from records of the daily volumes of coatings used multiplied by the VOC content specified by the manufacturer.
The above restrictions do not limit potential to emit since the source has the physical capacity to exceed the 50 tpy threshold limit for VOC RACT rule applicability under 6 NYCRR Part 228. A monthly limit on gallons of coating used which when multiplied by 3.0 lb/gal equates to less than the 50 tpy threshold (e.g. 2,700 gallons/month), with appropriate record keeping, would generally be necessary to limit the potential to emit. If, however, the Department determines, due to the wide variety of coatings employed and products produced, that restrictions on operation or production are not practically enforceable, then the above emission limits could restrict the potential to emit if there are requirements that the source calculate the VOC emission rate on a daily basis, and maintain appropriate records.
An alternate method of restricting the potential to emit would be to employ add-on controls to meet the 4 ton/month limit. In this case, the permit would need to contain an operational limit, such as the requirement to install and operate an incinerator at 99% efficiency. A requirement to monitor incinerator efficiency (either directly or indirectly via temperature monitoring as an example), and appropriate record keeping requirements to verify compliance with each of the permit conditions would also be necessary to make the permit conditions enforceable as a practical matter. The permit reviewer should note that in the case where add-on controls are to be used, the source may be able to meet a shorter term emission limit than the ton per month value.
- Restrictions on Design Capacity Utilization
Example #1 - The potential to emit of a boiler with a design input capacity of 200 MMBTU/hr is limited to a 100 MMBTU/hr fuel input rate by the permit, which requires that the Boiler's heat input not exceed 50% of its rated capacity. The permit would need to further require that compliance be demonstrated with a continuously recording fuel meter and concurrent monitoring and recording of fuel heating value to show that the fuel input does not exceed 100 MBTU/hr.
Example #2 - A #4 oil fired stone drier, permitted prior to 7/1/73 has the following characteristics: maximum process weight of 50,000 lbs/hr, 140 tpy particulate emission limit; a maximum concentration of 0.1 gr/dscf; a maximum permitted emission rate of 32 lbs/hr as per Table 4, Part 212.9; a maximum flow rate of 37,000 dscfm based on nameplate capacity; continuous operation; baghouse with a 90% overall reduction efficiency of particulate matter.
The facility decides to limit its potential to emit to 98 tpy in order to cap out of Title V requirements (100 tpy PM-10). For lack of data, all emitted particulates are assumed to be PM-10, which is a conservative assumption. One method by which this could be accomplished is by limiting the feed rate to 70% of the nameplate capacity. One of the enforceable limits becomes a stone feed rate (tph) based on 70% of nameplate capacity with a federally enforceable requirement for a method or device for measuring the feed rate on an hourly basis. In addition, provisions should be made for recording the quantity either automatically or manually via a written log.
An alternate approach would be to limit the particulate emission rate to 22 lbs/hr. In this way the permit contains a short term emission limit (in addition to the annual emission limit) consistent with the compliance period or parameter in the applicable test method for determining compliance.
A third alternative would be to retain a maximum concentration of 0.1 gr/dscf and limit the maximum exhaust flow rate to 26,000 dscfm due to the decrease in feed rate. In all these cases, the 90% overall reduction of particulate emissions on an hourly basis via capture hoods and baghouse would be maintained and further conditions would be implemented listing appropriate operating parameters for the baghouse which could then be used to verify proper operation of the control device.
It is important to note that this example focused on particulate emissions. Since NOx, SO2, and or CO emissions could be significant, these would also need to be evaluated separately for possible Title V applicability.
- Restrictions on Hours of Operation (including seasonal operation)
Example #1 - Using the stone drier scenario discussed in the previous example, the operator may choose to limit the hours of operation per year to keep the potential to emit below the Title V applicability threshold of 100 tpy. Assuming the same maximum concentrations, flow rate and minimum overall control efficiency limitations as discussed previously, a restriction on the number of 8-hour shifts to two, i.e., 16 hours per day would reduce the potential uncontrolled emissions by 33% to 94 tpy. The source would also be required to maintain appropriate records to document the hours of operation.
Example #2 - A minor source construction permit for an residual oil fired boiler contains the following restrictions: 250,000 gallon fuel/month; 0.8% S fuel; 8,000 hrs/yr.
The above conditions are federally enforceable production and operation limits, but do not limit the potential to emit because one of them cannot be enforced as a practical matter. The averaging time for hours of operation, one of the operational limits necessary to restrict emissions to less than the major PSD threshold of 250 tpy, exceeds a monthly or rolling yearly limit. If, instead of 8000 hrs/yr, the hourly restriction were stated as 666 hours/month, the permit would serve to keep the source a minor source, assuming the permit contains appropriate record keeping provisions.
- Restrictions on the Types or Amount of Material Processed, Combusted or Stored
Example #1 - Sulfur content in the coal feed for a power plant is limited to a maximum of 1% by weight.
Example #2 - A surface coater is limited to using only water-based or higher solids coatings with a maximum VOC content of 2.0 lbs VOC per gallon solids deposited on the substrate with requisite limits on coating usage (gallons/hr or gallons/yr) on a 12-month rolling time period.


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Hold-Out Your HeartJon Regen
Almost Home
CD/LP/Track Review
- Almost Home by Rob Cline
Almost Home
Almost Home (HiTone) by Jon Regen
Broken link? Report it to us
From the 2004 release Almost Home, a seven-song EP of all-original material that showcased Regen's previously hidden talents as a singer and songwriter. Critics around the globe heralded the new music with unanimous praise; ALL MUSIC GUIDE awarded it Four Stars, and CDBABY proclaimed Regen has woven a tapestry of adult contemporary pop and jazz that reflects on the integration of intelligent songwriting with the elemental and unbridled force of the human spirit. The Danube Courier dubbed Regen the Miracle Child from New York, and High Bias called the EP a collection of solid tunes with instantly-appealing melodies and soulful vocals. Featuring Jonathan Sanborn and Eric Addeo
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General Motors recalls about 60,000 Chevy Malibu cars
Leading US automaker General Motors Corporation issued two recalls for about 60,000 Chevrolet Malibu sedans due to problems with power seat wiring and the heating, ventilation and air conditioning system.
According to a report, the Detroit-based auto giant is recalling 14,930 Malibu cars of the 2013 model from North America because wiring beneath the seats can catch fire, reported Xinhua Friday.
Meanwhile, 44,406 Malibu sedans of the 2014 model are also being recalled because the heating, ventilation and air conditioning system (HVAC) controls may not operate properly when the engine is turned on.
If the HVAC control is not operating, the system will revert to the setting selected when the vehicle was last driven. If that setting was not in defrost mode, the driver may be unable to clear the windshield, which could lead to decreased visibility, explained the corporation.
The recall reportedly involves 42,696 Malibus in the US, 1,034 in Canada and 676 in Mexico. General Motors dealers will re-programme the HVAC control module without cost to customers.
General Motors recalled nearly 340,000 Chevrolet Cruze cars globally Aug 16 due to a possible loss of brake-assist in the vehicle.
(Posted on 16-11-2013)


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|Issue 12.11 - November 2004
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Flesh-and-blood soldiers could become the weakest link in the military chain, according to Darpa, the Pentagon's way-out research division. The solution? Stop the bleeding. Soldiers die if they lose too much blood. But currently battlefield medics can't do enough to stanch the flow from some gaping wounds, and synthetic blood substitutes don't make up for the loss.
One approach is being studied by the agency's Surviving Blood Loss project. When marine mammals like whales and seals dive deep, they let sections of their bodies go cold, cutting their metabolic rates dramatically. Darpa hopes that drugs or tech might allow soldiers to pull off the same trick - the agency's goal is to enable a rat to survive more than six hours after 60 percent of its blood has been drained.
Even Darpa managers admit it's far-fetched. Plan B: minimize bloodshed at the source, including spurting arteries. The Deep-Bleeder Acoustic Coagulation project, which aims to build on the work of researchers at the University of Washington and elsewhere, uses focused, intense sonic blasts to heat the damaged cells. "Focused ultrasound allows a noninvasive method of cauterizing" - without fire or a laser -�say the researchers. Darpa's looking for a portable emitter for combat that doesn't need an expert operator. That military chain's getting tougher.
- Noah Shachtman


text:
AUGUSTA, Maine (AP) - Maine Gov. Paul LePage says he's going to veto the two-year budget that contains temporary tax increases.
LePage made the announcement Thursday at an Americans For Prosperity rally dubbed "Don't Overtax ME" at the State House.
The Republican governor previously threatened to veto the $6.3 billion state budget, saying a potential state government shutdown in the short term would be better than adopting a budget that includes tax increases.
The budget includes temporary sales tax and meals and lodging tax increases.
Lawmakers plan to reconvene next week to take up the budget. A budget proposal must be in place by July 1 to avoid a government shutdown.
(Copyright 2013 The Associated Press. All rights reserved. This material may not be published, broadcast, rewritten or redistributed.)


text: Robert Weenolsen | IBDB: The official source for Broadway Information IBDB: The official source for Broadway Information Official Broadway League sites: - sites - broadway.org broadwayleague.com broadwayfanclub.com kidsnightonbroadway.com stagespecs.org tonyawards.com Quick Search For: In This Category: All Show People/Org. Theatre Season Robert Weenolsen Producer, Writer Male Productions ProductionsDate of ProductionsLend Me Your Ears![Play, Comedy, Original] Produced by Robert Weenolsen Oct 05, 1936 - Oct 1936Honest Liars[Play, Farce, Original] Written by Robert Weenolsen Jul 19, 1926 - Oct 1926 Find out where Robert Weenolsen and are credited together © 2001-2015, The Broadway League, All Rights Reserved. (Copyright and Disclaimer)


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Shakespeare on the Common: Two Gentlemen of Verona
Presented by Commonwealth Shakespeare Company at Boston Common
July 6 - July 28, 2013
Commonwealth Shakespeare Company's Free Shakespeare On The Common is one of Greater Boston's most beloved traditions. For their 18th annual season, Commonwealth Shakespeare Company is excited to present the comedy The Two Gentlemen of Verona July 6 - 28, 2013.
Directed by the company's Artistic Director Steven Maler, The Two Gentlemen of Verona tells the tale of two friends who leave their hometown of Verona to find their happy fortunes in Milan. Instead, they find temptation, trickery, and trouble as they vie for favor with the high-society Duke... and his debutante daughter. All are drawn into a web of disguise and secrecy where the last thing anyone wants is for the truth to surface - least of all the dog. Inspired by Rat Pack-era Vegas – the glamour, the hedonism, and the morning after agonies – the production brings new meaning to the line "what happens in Milan, stays in Milan."
The performance schedule is July 6 at 8pm; July 7 at 7pm; July 8-12 at 8pm; July 14-15 at 8:30pm; July 17 at 8:30pm; July 18 at 1pm; July 21 at 7pm; July 23-26 at 8pm; July 27 at 2pm & 8pm; and July 28 at 7pm. Free and open to the public.
For reserved chairs and to order picnic boxes, visit http://www.commshakes.org/support-us/reserved-seats.
For information on our Acting Apprentice Company and Tour of the Parks, visit http://www.commshakes.org/performances/performance/30.
For information on Family Day and Free Fun Friday in conjunction with the Highland Street Foundation, visit http://www.commshakes.org/performances/performance/31.
Tremont and Park Street
Boston, MA
Admission Info:
Phone: 617-426-0863
Accessibility Information:
ASL-interpreted performances on July 21st at 7PM and July 27th at 2PM. Audio-described performance on July 18th at 1PM.


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The city of Los Angeles is striping more bike lanes and increasing the visibility of crosswalks in an effort to make streets safer for pedestrians and cyclists. Above, a cyclist walks her bike in downtown L.A. during last month's CicLAvia. Los Angeles Times
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Future Pope Pius XII backed Jewish homeland in Palestine
Catholic World News - March 09, 2012
Documents unearthed by the Pave the Way Foundation show that Msgr. Eugenio Pacelli supported a Jewish homeland in Palestine.
In 1917, the future Pope Pius XII met with Nahum Sokolow of the World Zionist Congress. According to a document unearthed in the archives of Yad Vashem, Sokolow said that "I can't avoid to stress that this revealed an extraordinary amount of friendship: to grant a Jew and representative of Zionism with such a promptness a private audience which took so long and was of such a warmth and took place with all assurance of sympathy, both for the Jews in general and for Zionism in special, proves that we don't need to expect any obstacles which can't be overcome from the side of the Vatican."
In 1917, according to the Pave the Way Foundation, Msgr. Pacelli urged the German government to protect Jews in Palestine from Ottoman reprisals, and in 1926, he urged German Catholics to support a Jewish homeland in Palestine.
"Our research has shown that Pope Pius XII's positive relationship with the Jewish people began in Pacelli's youth with his close childhood friend, an Orthodox Jewish boy named Guido Mendes," said Elliot Hershberg of the Pave the Way Foundation. "Pacelli would share in Shabbat meals, he learned to read Hebrew and borrow the books of the great rabbinic scholars."
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One wonders if even this will silence the "Hitler's Pope" calumny heaped upon this saintly man.


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The Honduran international midfielder will be registered on September 1 when the club's transfer embargo is lifted but will join Ally McCoist's squad for pre-season.
24-year-old Peralta is currently part of Luis Suarez's international side which, having kicked off its summer of football against Israel in New York on Sunday, faces matches with Costa Rica and the USA in the next fortnight.
The former Vida star will then be free to fly to Glasgow to join Jon Daly, Nicky Clark, Cammy Bell and Nicky Law as a new addition to McCoist's squad.
And even though he won't have had much of a break Arnold can't wait to team up with McCoist and his players.
He said: "I am delighted to be joining a club with the size and history of Rangers. I had several offers from Europe, MLS and at home in Honduras but when I was told I could sign for Rangers it was an easy decision.
"I am really looking forward to pulling on that famous blue shirt and getting out on the Ibrox pitch, hopefully the club and fans will appreciate what I can bring to the team."
McCoist said: "We are delighted Arnold has agreed to join us. We went over and watched him playing for Honduras against Panama and he performed well.
"He will certainly give us a bit of bite in the middle of the park. He actually played at right-back when we saw him but his best role is sitting in midfield.
"Arnold is very aggressive and he gets about the park well so I think he would blend in with the rest of the midfield and he will be a good signing.
"It's great we are signing a Honduran international who is of a good pedigree and playing in World Cup qualifiers."
The midfield player has, of course, been in Glasgow before. One of his caps was won in a match against Morocco at Hampden in last summer's Olympic Games.
He featured in three matches at the Games and has been a regular in his country's national side since.
Copyright 2014. Permission to use quotations from this article online is only granted subject to appropriate source credit and hyperlink to www.rangers.co.uk


text:
The timing, route, and process of the first colonization remain contentious issues in North American archaeology. Nonetheless, most archaeologists subscribe to the land bridge theory. Indeed, some of the oldest evidence of Paleo-Indians can be found in northwestern North America. Sites in Alaska have yielded tools and other cultural remains, including small teardrop-shaped projectile points called Chindadn points. Archaeologists call this group the Nenana complex (Hamilton and Goebel, 1999). They hunted sheep, elk, and birds. About 1,000 years later, a new technology developed in the Arctic based on microblades, which are specialized stone flakes used to make composite hunting tools. Little is known about the lifeways of these later Paleo-Indians, named the Denali complex. They likely hunted both land and marine animals (e.g., caribou and fish).
While Alaska was mostly ice-free during the last Ice Age, much of Canada was covered by a thick ice sheet that blocked early Paleo-Indian migration into the contiguous United States. There were two possible migration routes from Alaska to the continental interior. The first is called the Ice-Free Corridor route, which was an opening east of the Rockies between the two large ice sheets that covered Canada. Paleo-Indians may have followed migrating animals southward through this corridor into the United States (Wilson and Burns, 1999). Some archaeologists, however, have questioned the Ice-Free Corridor theory. Archaeological sites south of the ice sheets, which may be older than the Ice-Free Corridor, suggest that another route may have been used. Early Paleo-Indians may have traveled down the West Coast, either on foot or by boat. Unfortunately, very early sites have not been found in this region, so the presence of early Paleo-Indians cannot be confirmed (Dixon, 1999).
In any discussion of prehistoric North America, two other perspectives should be mentioned. Some archaeologists propose that North America was colonized long before 10,000 BCE, perhaps as early as 30,000 BCE (Dixon, 1999). They point to the presence of a few archaeological sites in North and South America that appear to predate Clovis times. Two of the best-known are Monte Verde in Chile, which has evidence for a Paleo-Indian occupation about one thousand years before Clovis times, and Meadow-croft Rockshelter in Pennsylvania, which may date as early as 16,000 BCE. The validity of these early sites is passionately debated among scientists. Alternatively, many Native Americans take issue with these archaeological theories because their oral histories state that their ancestors have lived in North America since the time of creation.
Although the specific route and timing of the first Paleo-Indian colonization remain contentious, there is widespread agreement that by 9500 BCE Paleo-Indians occupied much of North America. The oldest archaeological sites often contain Clovis spear points, associated with the remains of now extinct animals like mammoth, megabison, and horses. Clovis spear points are distinguished by their flutes, which are large channel-like flake scars that typically reach from the point's base to its midsection. Because of this feature, they are often called fluted points. The extensive occurrence of Clovis sites has led some archaeologists to suggest that the distribution indicates a single widespread cultural group, while others maintain that the distribution results from the rapid transfer of a new technology (the Clovis projectile point) from group to group.
Clovis hunter-gatherers were very proficient at killing large mammals, though they also utilized a wide range of smaller animals and plants. The first appearance of Clovis hunters in North America coincided with the extinction of many large mammal species (e.g., mammoth, horse, and camel). This has led some to argue that the first Paleo-Indians hunted these animals to extinction. Although there is little doubt that early Paleo-Indians were highly skilled hunters, it is likely that the rapidly changing climate of the last Ice Age contributed to these extinctions.
Paleo-Indians in the Great Basin region of western North America used two different technologies between 10,000 and 8000 BCE. Some of the earliest sites contain projectile points similar to the Clovis-style, whereas others contain stemmed points. These different technologies may represent multiple Paleo-Indian groups living in the region at the same time or a cultural change over time. Unlike their neighbors on the Great Plains, Paleo-Indians from the Great Basin appear to have focused their diet on waterfowl, fish, and small mammals rather than big game.
The Great Plains region has some of the best evidence for early Paleo-Indian lifeways, with abundant Clovis sites dated between 10,000 and 9000 BCE. Distinctive Clovis fluted points are often found associated with the remains of large mammals. Between 9000 and 6000 BCE several other Paleo-Indian groups inhabited the Great Plains, including Folsom, Agate Basin, Hell Gap, Alberta, and Cody. Because many large mammals went extinct during the Clovis period, these later Paleo-Indians focused instead on bison hunting. They used natural and constructed traps to contain large herds of bison to kill dozens of animals at once. Most aspects of Plains Paleo-Indian lifeways were connected to the bison.
Eastern North America was home to different groups of Paleo-Indians. Since environments in the east differed from those in the west, Paleo-Indians in this region used different hunting methods and toolkits (Storck, 2004). Early projectile points found in the east are similar to their western counterparts (often fluted) but include small differences in overall shape. Some common types of eastern Paleo-Indian projectile points include Gainey, Parkhill, Crowfield (in the northeast), and Cumberland and Suwannee (in the southeast). Unfortunately, the cultural chronology is not as well understood in the east as it is in the west. Eastern Paleo-Indians were proficient hunters, able to kill mastodon, caribou, and other large mammals. They were probably more generalized than their Great Plains counterparts, using a wide range of animals and plants in their diets.
Much of what we know about Paleo-Indian life-ways comes from their stone tools and hunting methods. The presence of tools made from stone originating over 1,000 kilometers away indicates that Paleo-Indians were highly nomadic. They lived in small bands comprised of several families, although they periodically formed larger social groups. They were highly skilled hunter-gatherers able to adapt quickly to new environments (Anderson and Gillam, 2000). Their main hunting technology was the spear and atlatl (spear thrower), which was tipped by specialized projectile points. We know little of their religion and beliefs, although there is some evidence for possible religious activity (Storck, 1991).
Jason David Gillespie
Further Reading
Anderson, David G., and J. Christopher Gillam. 2000. "Paleoindian Colonization of the Americas: Implications from an Examination of Physiography, Demography, and Artefact Distribution." American Antiquity 65: 43–66.; Dixon, E. James. 1999. Bones, Boats and Bison: Archeology and the First Colonization of Western North America. Albuquerque: University of New Mexico Press.; Hamilton, Thomas D., and Ted Goebel. 1999. "Late Pleistocene Peopling of Alaska." In Ice Age Peoples of North America: Environments, Origins, and Adaptations. Edited by Robson Bonnichsen and Karen L. Turnmire, 156–199. Corvallis: Oregon State University Press.; Storck, Peter L. 1991. "Imperialist Without a State: The Cultural Dynamics of Early Paleoindian Colonization as Seen from the Great Lakes Region." In Clovis: Origins and Adaptations. Edited by Robson Bonnichsen and Karen L. Turnmire, 153–162. Corvallis: Center for the Study of First Americans.; Storck, Peter L. 2004. Journey to the Ice Age: Discovering an Ancient World. Vancouver: University of British Columbia Press.; Wilson, Michael Clayton, and James A. Burns. 1999. "Searching for the Earliest Canadians: Wide Corridors, Narrow Doorways, Small Windows. " In Ice Age Peoples of North America: Environments, Origins, and Adaptations. Edited by Robson Bonnichsen and Karen L. Turnmire, 213–248. Corvallis: Oregon State University Press.


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Steve Schlather is a patent lawyer and litigator. His clients range from small, start-up companies and individual inventors to large, multinational corporations. For more than 10 years, Steve has represented both plaintiffs and defendants under a variety of fee arrangements, including on an hourly, fixed-fee and contingent fee basis.
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Prior to joining Collins, Edmonds & Pogorzelski, Steve was a patent litigator at Susman Godfrey LLP in Houston.
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The MikadoItem #: HL.35014259
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Composed by Gilbert & Sullivan. Arranged by M.J. Arnold.
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The delightful saga of The Mikado is arranged for 2-part chorus with all the favorite leading characters. You'll love the comic twists in this fun classic. A great exposure for your students to the legacy of operetta and musical theater. Sixteen vocal numbers (plus an optional 17th), overture and condensed dialogue make for a wonderful school musical event. Grade Level: 6-9; Perf. Time: Approx. 60 minutes


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MADISON -- Plastics are everywhere in our modern world, largely due to properties that render the materials tough and durable, but lightweight and easily workable. One of their most useful qualities, however - the ability to bend rather than break when put under stress - is also one of the most puzzling.
This property, described as "plastic flow", allows many plastics to change shape to absorb energy rather than breaking apart, says University of Wisconsin-Madison chemistry professor Mark Ediger. For example, one type of bulletproof glass stops a bullet by flowing around it without breaking. Regular window glass, unable to flow in this way, would simply shatter.
"This is an odd combination of properties... These materials shouldn't be able to flow because they're rigid solids, but some of them can," he says. "How does that happen?"
Ediger's research team, led by graduate student Hau-Nan Lee, has now described a fundamental mechanism underlying this stiff-but-malleable quality. In a study appearing Nov. 28 in Science Express, they report that subjecting a common plastic to physical stress - which causes the plastic to flow - also dramatically increases the motion of the material's constituent molecules, with molecular rearrangements occurring up to 1,000 times faster than without the stress.
These fast rearrangements are likely critical for allowing the material to adapt to different conditions without immediately cracking.
Plastics are a type of material known to chemists and engineers as polymer glasses. Unlike a crystal, in which molecules are locked together in a perfectly ordered array, a glass is molecularly jumbled, with its constituent chemical building blocks trapped in whatever helter-skelter arrangement they fell into as the material cooled and solidified.
While this atomic disorder means that glasses are less stable than crystals, it also provides molecules in the glass with some wiggle room to move around without b
|Contact: Mark Ediger
University of Wisconsin-Madison


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> Chick-fil-A
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Chick-fil-A has donated money to organizations that oppose same-sex marriage.
[Collected via e-mail, March 2012]
Let's all eat at Chick-Fil-A this week.
Now the Socialists (AKA Obama Democrats) have targeted
a Southern based company with the below resume.
I think, I'll have a Chick-Fil-A sandwich tomorrow.
Chick-fil-A is an American success story. Founded by Georgian entrepreneur Truett Cathy in 1946, the family-owned chicken-sandwich chain is one of the country's largest fast-food businesses. It employs some 50,000 workers across the country at 1,500 outlets in nearly
40 states
and the District of Columbia ... The company generates more than
$2 billion
in revenue and serves millions of happy customers with trademark Southern hospitality.
So, what's the problem? Well,
is run by devout Christians who believe in strong marriages, devoted families, and the highest standards of character for their workers. The restaurant chain's official corporate mission is to "glorify God" and "enrich the lives of everyone we touch." The company's community-service initiatives, funded through its WinShape Foundation, support foster-care, scholarship, summer-camp, and marriage-enrichment programs. On Sunday, all
stores close so workers can spend the day at worship and rest.
Over the past month, several progressive-activist blogs have waged an ugly war against
The company's alleged atrocity: One of its independent outlets in Pennsylvania donated some sandwiches and brownies to a marriage seminar run by the Pennsylvania Family Institute, which happens to oppose
In the name of tolerance, the anti-Chick-fil-A hawks sneered at the company's main product as "Jesus Chicken," derided its no-Sunday-work policy, and attacked its operators as
Petition drives on websites are demanding the company change and disavow their standards. Facebook users dutifully organized witch hunts against the company on college campuses.
Progressive groups are gloating over Chick-fil-A's public-relations troubles. This is not because they care about winning hearts and minds over gay rights or marriage policy, but because their core objective is to marginalize political opponents and chill Christian philanthropy and activism. The fearsome "muscle flexing" is being done by the hysterical bullies trying to drive them off of college grounds and out of their neighborhoods in the name of "human rights."
Clearly the Christian business man who lives what he believes deserves our support....Thank God that some people are strong enough to stand up for what they believe even in the face of assault and ridicule from those who have no integrity....Let's all eat at
Let�s all eat Chick-Fil-A! Truet Cathy founded a wonderful company who hires teenagers and pays their way to college. Not only that, it is delicious. These people are undermining American strongholds in order to weaken us for the enemy within and the enemy without!
Please pass this on if you believe companies with Christian principles have a right to freely conduct business in the U.S.
Chick-fil-A is a Georgia-based fast food restaurant chain specializing in chicken entr�es that opened its first outlet in suburban Atlanta in 1967 and has since grown to encompass over
1,600 restaurants
39 states.
The operations of the chain reflect the religious values of Founder, Chairman and Chief Executive Officer
S. Truett
Cathy, whose
notes that he has "built his life and business based on hard work, humility and biblical principles" and that "based on these principles, all of
restaurants operate with a 'Closed-on-Sunday' policy, without exception."
Chick-fil-A has been the subject of political controversy due to its WinShape Foundation, a charitable endeavor founded by
S. Truett
Cathy and his wife, Jeanette, which critics contend has evidenced a bias in the
company by
millions of dollars to groups with
agendas. As a result,
has recently faced opposition from students at ten U.S. universities, including
New York
University (NYU), who have circulated petitions to oppose the opening of new
franchises on their campuses and lobbied for the removal of existing restaurants. The company has maintained that neither they nor the organizations they donate to through WinShape has an
The student senate at Northeastern University, in Boston, voted to end negotiations to bring fast-food chain
to campus after students protested over the company's affiliation with several Christian organizations the students say have an
The Atlanta-based company, dogged for months by accusations of homophobia, insists it is "not anti-anybody" but instead simply wants to "graciously serve great food and have a positive influence on all who come in contact with
Company president Dan Cathy insists
is not a Christian company, just one founded on biblical principles. But thanks in part to the company's affiliation with
groups, its frequent presence at large religious rallies and the praise music reverberating from speakers in its restaurants, both fans and detractors often refer to it as one of the country's most overtly Christian businesses.
Through the WinShape Foundation, started by company founders Truett and Jeannette Cathy,
donates to several Christian organizations, including The Marriage & Family Legacy Fund, The Fellowship of Christian Athletes and the National Christian Foundation. According to its statement,
has given the groups $1,714,199. None of the organizations the company supports has an
agenda, although as Christian groups, they do uphold and support heterosexual marriage,
Donald A.
Perry, the company's vice president of corporate public relations, said in his statement.
"I want to assure you that the historical intent of our Foundation and corporate giving have been toward compassion, principally by serving youth and families," he said. The company gives millions of dollars every year toward education.
president and chief operating officer Dan Cathy's July 2012
with the
Baptist Press
generated even more controversy over the issue, with critics maintaining he had virtually acknowledged the company supports an
marriage agenda:
Chick-fil-A is "very much supportive of the family," according to Dan Cathy, president of the popular fast food chain. That is, "the biblical definition of the family unit," he said.
And that doesn�t include Adam and Steve, suggests Cathy, whose father
S. Truett
Cathy founded the Atlanta-based company.
In a new interview with Baptist Press, Cathy puts on the record what critics say his company�s actions have indicated for years. "Well, guilty as charged," he said in the interview when asked about
backing of families led by a man and a woman.
The controversy took flight in mid-July after Cathy gave an interview to the Biblical Recorder, on online journal for Baptists in North Carolina. In the July 2 story � picked up by the Baptist Press on July 16 � Cathy affirmed that his company backs the traditional family unit.
�We are very much supportive of the family � the biblical definition of the family unit,� Cathy said. �We are a family-owned business, a family-led business, and we are married to our first wives. We give God thanks for that.�
"I think we are inviting God's judgment on our nation when we shake our fist at Him and say 'we know better than you as to what constitutes a marriage' and I pray God's mercy on our generation that has such a prideful, arrogant attitude to think that we have the audacity to define what marriage is about," Cathy also said during an appearance on the Ken Coleman talk show.
Proponents of same-sex marriage spread Cathy�s comments, eventually creating a firestorm of criticism on social media, including assertions that his comments and position were bigoted and hateful.
The public reaction to Cathy's remarks prompted Chick-fil-A to issue the following statement:
The Chick-fil-A culture and service tradition in our restaurants is to treat every person with honor, dignity and respect � regardless of their belief, race, creed, sexual orientation or gender. We will continue this tradition in the over 1,600 Restaurants run by independent Owner/Operators. Going forward, our intent is to leave the policy debate over
marriage to the government and political arena.
This controversy prompted readers to ask us about a number of related ancillary issues detailed below:
Yes, it is true that in July 2012, the Jim Henson Company announced it was severing its partnership with
to supply toys for the chain's children's meals:
Chick-fil-A had recently joined forces with the Jim Henson Company to offer five customizable puppet toys from Jim Henson's Creature Shop in children's meals.
But after the Atlanta-based family-owned business made headlines when its president, Dan Cathy, told the Baptist Press recently that the company was "guilty as charged" when it came to not supporting marriage equality and standing by biblical family values, the Henson Company decided to end the partnership.
Shortly afterwards, some Chick-fil-A outlets posted
indicating the chain was initiating a voluntary "withdrawal" or "recall" of the Henson-produced toys:
The Jim Henson Company announced it would no longer partner with
in the wake of the fast food company's acknowledged support of anti-gay organizations. Now, however,
officials are reportedly telling franchise customers that the kids' meal toys which were produced as part of the now-severed collaboration have been recalled due to safety issues.
Chick-Fil-A spokeswoman Tiffany Greenway [said] that the company had decided to recall the Muppets toys nationwide "for the protection of our customers." She said it was a decision completely separate from the Jim Henson Company's announcement.
It was also true that Boston mayor Thomas M. Menino sent a
president Dan Cathy urging the company to reconsider its plans to open an outlet in Boston (although the mayor's ability to enforce his suggestion without running afoul of first amendment restrictions is questionable):
Mayor Thomas M. Menino is vowing to block
from bringing its Southern-fried fast-food empire to Boston � possibly to a popular tourist spot just steps from the Freedom Trail � after the family-owned firm�s president suggested gay marriage is "inviting God�s judgment on our nation."
"Chick-fil-A doesn�t belong in Boston. You can�t have a business in the city of Boston that discriminates against a population. We�re an open city, we�re a city that�s at the forefront of inclusion," Menino [said].
"That�s the Freedom Trail. That�s where it all started right here. And we�re not going to have a company,
or whatever the hell the name is, on our Freedom Trail."
A couple of widely-circulated pieces about Chick-fil-A and other fast food outlets were merely bits of satirical political humor, not genuine news items: On 24 July 2012, the satirical
web site spoofed the Chick-fil-A controversy by
an article titled
Debuts New Homophobic Sandwich":
As part of its recent efforts to publicly align itself with fundamentalist Christian values, the
restaurant chain announced the debut of its new Queer-Hatin' Cordon Bleu sandwich that would be on sale in all of the company's
1,600 restaurants.
In a press conference to reporters, company representatives said the homophobic new sandwich will include the national fast food chain�s trademark fried chicken filet wrapped in a piece of specially-smoked
No Homo
ham that would be topped with a slice of Swiss cheese and lathered in a creamy new Thousand Island-based Fag Punching sauce.
A similar Onion blurb spoofing the Chick-fil-a controversy was
on 30 July 2012:
Responding to Chick-fil-A CEO Dan Cathy's recent controversial admission of the company's donations to antigay groups, a statement from competing fast food chain Wendy�s let consumers know that it has long supported
couples and only harbors strong objections to interracial marriage.
"It's important that Wendy�s customers know our restaurant proudly stands by the right of all Americans to marry whomever they choose, so long as it isn't someone of a different race,� said spokeswoman Jenna Knox, adding that while Wendy�s has always backed
legislation, it found miscegenation "an abominable offense to God�s will."
"Just like our founder Dave Thomas, we dream of living in an America where two loving people of the same sex can freely wed, provided of course that both people are also of the same race, and that no black, Asian, Latin American, or other
heritage is allowed to de-purify the white racial bloodline."
Following the Wendy�s statement, executives from Jack in the Box confirmed that they too had always supported gay rights and the Holocaust never happened.
As we detailed in a separate
, various images of signs from other fast food signs offering support or criticism of Chick-fil-A were digital fabrications, not real photographs.
Some readers asked, "Did Chick-fil-A really spend millions lobbying Congress not to condemn Uganda�s 'Kill the Gays' bill"? We found no evidence that Chick-fil-A itself spent money (let alone millions) lobbying Congress to prevent that body from issuing a condemnation of a controversial Ugandan
legislative bill
which carried the death penalty for some homosexual acts. Some sources reported that the Family Research Council (FRC), one of the organizations to which Chick-fil-A donates through its WinShape corporate charity foundation, filed a
stating that it had spent $25,000 lobbying Congress against
, a resolution seeking to "express the sense of the House of Representatives" that Uganda's proposed Anti-Homosexuality Bill "threatens the protection of fundamental human rights." However, the FRC said that although they did perform lobbying activities regarding
they did not support the Uganda bill or the death penalty for homosexuality, and their lobbying efforts were not aimed at killing the Congressional resolution but rather at changing its language "to remove sweeping and inaccurate assertions that homosexual conduct is internationally recognized as a fundamental human right."
In September 2012, the Civil Rights Agenda group reported that Chick-fil-A had pledged not to fund groups that oppose gay marriage:
Chick-fil-A has pledged to stop giving money to anti-gay groups and to back off political and social debates after an executive�s comments landed the fast-food chain smack in the middle of the gay marriage debate.
The Civil Rights Agenda, which dubs itself the largest lesbian, gay, bisexual and transgender advocacy group in Illinois, said Chick-fil-A agreed in meetings to stop donating to groups such as Focus on the Family and the National Organization for Marriage. Such groups oppose same-sex marriage.
Chick-fil-A said that its nonprofit arm, the WinShape Foundation, �is now taking a much closer look at the organizations it considers helping, and in that process will remain true to its stated philosophy of not supporting organizations with political agendas,�
Shortly afterwards, Chick-fil-A issued an ambiguous statement about whether it had in fact made any such pledge:
For many months now, Chick-fil-A�s corporate giving has been mischaracterized, and while our sincere intent has been to remain out of this political and social debate, events from Chicago have once again resulted in questions around our giving. For that reason, we want to provide some context and clarity around who we are, what we believe and our priorities in relation to corporate giving.
A part of our corporate commitment is to be responsible stewards of all that God has entrusted to us. Because of this commitment, Chick-fil-A�s giving heritage is focused on programs that educate youth, strengthen families and enrich marriages, and support communities. We will continue to focus our giving in those areas. Our intent is not to support political or social agendas.
As we have stated, the Chick-fil-A culture and service tradition in our restaurants is to treat every person with honor, dignity and respect � regardless of their belief, race, creed, sexual orientation or gender. We will continue this tradition in the over 1,600 restaurants run by independent Owner/Operators.
Last updated:
21 September 2012
Urban Legends Reference Pages � 1995-2015 by snopes.com.
This material may not be reproduced without permission.
snopes and the snopes.com logo are registered service marks of snopes.com.
Aarthun, Sarah. "Chick-fil-A Wades Into a Fast-Food Fight Over Same-Sex Marriage Rights."
. 28 July 2012.
Dardick, Hal. "Moreno Relents, Will Allow Chick-fil-A."
Chicago Tribune
. 19 September 2012.
Hanna, Jason. "How the Chick-fil-A Same-Sex Marriage Controversy Has Evolved."
. 27 July 2012.
Hsu, Tiffany. "Is Chick-fil-A Anti-Gay Marriage?"
Los Angeles Times
. 18 July 2012.
Hsu, Tiffany. "Chick-fil-A Promises to Stop Giving Money to Anti-Gay Groups."
Los Angeles Times
. 12 September 2012.
Montopoli, Brian. "FRC Lobbied Congress on Resolution Denouncing Ugandan Anti-Gay Bill."
. 4 June 2010.
Randazaa, Marc J. "Chick-fil-A and Free Speech."
Los Angeles Times
. 31 July 2012.
Reiner, Anne. "Chick-fil-A's Christian Ties Stir College Opposition."
Baptist Press
. 8 March 2012.
Schlanger, Zo�. "NYU Decided to Keep 'Homophobic' Chick-fil-A Long Before Petition Launched."
. 5 March 2012.
Schmall, Emily. "The Cult of Chick-fil-A."
. 23 July 2007.
Yang, Emily. "Students Urge for Ban of Chick-fil-A."
Washington Square News
. 1 March 2012.
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text:
'The Office' Season 7, Episode 1 (Premiere) Recap (VIDEO)
What do you do when a season premiere starts with such great promise then lays an egg? And what would you do if that premiere is starting a critical season for a long-running show that's losing its lead at the end of the it?
What you is let out a huge sigh and pray that Steve Carell's last season on 'The Office' isn't going to be a huge disappointment.
The lip dub opening -- using the tune 'Nobody But Me' by the Human Beinz -- was such a great way to smash into season 7, wasn't it? It reminded me of all the lip synch openings Drew Carey used to do on his show, but without all the choreography or panache. From Kelly and Ryan arguing over Ryan promoting his Wouhf social network, to Stanley going to Toby the cameraman "You'd better catch up," to Creed playing the guitar while fielding calls, to Michael's inability to lip-synch and do lame magic at the same time, it was 'The Office' at it's near finest. It was so good, I'll attach it to the bottom of this review.
My love of the cold open made me hopeful. The rest of the episode got me depressed.
It's not even that I'm disappointed that the story threads left hanging last season weren't addressed, except for the fact that Dwight bought the building (more on that in a bit). Those threads will be addressed at some point. So, even though Michael was left with the hope that Jo Bennett would somehow bring Holly Flax back to the Scranton office, it was fun to hear about his adventures with West Nile and peeing on his foot over the summer.
But the only other summer story that stuck out was Darryl's, mainly because he started talking about his softball injury and watching a lot of CNN and how we should get out of Afghanistan... then veers to how bad the new assistant is.
Which is when we devolved into yet another story where Michael acts strange in order to service the episode's comedy. It's not beyond the realm of possibility that he'd hire his nephew, especially if he needed to reconnect with him. After all, he did leave Luke in the forest 15 years ago (point of reference: 'Ace Ventura II'), so he owed the kid one.
But even in his dumbest moments, Michael wouldn't put up with the kid's insubordinate behavior for very long. Or he would have already told people who the kid was so they could treat him differently from the start. There's no way he would keep the detail that the two of them were related a secret for as long as he did. Sure, he'd equate giving Luke a job to God employing his son Jesus. But that's the type of thing that Michael Scott can do in his sleep.
So we get the spanking. That felt so odd and inappropriate, almost as odd and inappropriate as Michael and Dwight kidnapping the pizza delivery kid a few years back, which was a creative low point for the show. Is Michael that spineless that he couldn't just say, "You're fired!"? In what world does he think that spanking a 20-year old kid that he barley knows is appropriate just because he's related to him? Again, Michael is capable of a lot, but here it felt like the writers needed to make him creepy, too, just to serve the plot.
It doesn't matter if Kevin thought it was "awesome" or that Andy (I think) praised Michael for his "Texas justice." It just felt icky to me. Even if it does set up those potentially explosive counseling sessions between Michael and Toby, the ends didn't justify the means there.
More stuff:
-- Beyond the first few scenes, we didn't really explore the notion of Erin dating Gabe. I do love that Erin thinks that his being tall is an achievement. "Thank God he's my boss, because I wouldn't have said yes to that first date if I didn't have to." Oh, poor, sweet, naive Erin.
-- Dwight owning the building has a lot of comedic potential, mostly in the area of Jim/Pam pranks. I thought the key thing was pretty good, until Pam ruined it with her infernal laughing. Her way of making up for it, messing with the elevator, didn't seem to be as funny to me, except for the fact that she wouldn't come off the stuck elevator for a good reason: "Don't want to get cut in half."
-- Kelly completely wasted her management training, didn't she? She now wears purple suits instead of purple blouses, but how did she go through the whole program and then call the Michael/Luke thing a "zoning" problem? Was it the notion of an "even playing field?"
-- Andy about Luke: "He called me the 'Nard Man.' I'm the Nard Dog. Nard Man is my dad."
-- Creed loved the debate among the "great minds" in the conference room, and was happy to have a "front seat," even though he was in the back. Even the worst episodes have good Creed moments.
-- I wonder why Michael didn't realize that Talbot's wasn't a store for guys. The scary thing is that the pants he ordered actually fit. I want to find where they got that late '80s era Honda CRX that Luke was hiding all the packages in, by the way. Those things could fly (mainly because they weighed 900 pounds).
'The Office' airs Thursdays at 9PM ET on NBC.
(Follow @joelkeller on Twitter.)


text:
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text: Cardell Twins | IBDB: The official source for Broadway Information IBDB: The official source for Broadway Information Official Broadway League sites: - sites - broadway.org broadwayleague.com broadwayfanclub.com kidsnightonbroadway.com stagespecs.org tonyawards.com Quick Search For: In This Category: All Show People/Org. Theatre Season Cardell Twins Performer ( est. circa. 1927 ) Primary Organization Members:Edith Cardell and Marion Cardell Productions ProductionsDate of ProductionsRufus LeMaire's Affairs[Musical, Revue, Original] Performer: Cardell Twins [Specialty Dance]Mar 28, 1927 - May 1927 Find out where Cardell Twins and are credited together © 2001-2015, The Broadway League, All Rights Reserved. (Copyright and Disclaimer)