Personal
Communication:
Between
Kevin
Pechulis,
U.
S.
EPA
RCRA
Hotline,
and
Industrial
Economics,
Incorporated
Date:
March
19,
1998
Content:
Kevin
Pechulis
answered
questions
regarding
tribal
governments'
permitting
authorities
under
the
HWC
MACT
standards.
According
to
Mr.
Pechulis,
tribal
governments
will
not
be
required
to
assume
any
permitting
responsibilities
associated
with
the
proposed
HWC
MACT
replacement
standards
because
permitting
authority
is
voluntary
for
non­
federal
government
entities.
He
added
that
no
tribal
governments
have
assumed
permitting
authority
to
date
although
the
Clean
Air
Act
does
allow
tribal
governments
to
implement
permitting
requirements.
