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I don't know. To me a permit means a few pages at most of factual information about the entity requesting the permit (no data processing required) with the results of any testing stapled to it.
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I have spent several hours over the months since testing started talking with 2 different people at DEC about the testing procedures, the permit application, the permit language, who JBII is working with, what DEC's experience has been with those supporting companies, and how DEC views this working relationship.
One thing became clear over time. DEC takes it's responsibilities very seriously. They want JBII to succeed for several reasons, but DEC isn't going to cut them any slack just because they want JBII to succeed.
DEC wants to see a solution to the plastic waste problem. JBII's P2O processor is great start on that. DEC wants to see the jobs created by JBII in the local area. DEC wants to see low pollution industries come to their area.
The permit application itself is not that complex a document as has been shown by people posting it on line. The supporting documents are another question altogether. There are required statistical analyses required by the testing protocols specified by both state and federal laws. There are certifications of testing procedures for compliance. If you look on line at CRA's web site as has been posted here, you see that after the final report is done, it is sent to other groups in house for peer review. After all that is done then the report is sent on to JBII and only then can JBII and DEC get down to discussing the details. I emailed the company and asked when the final report came back from CRA. JBI didn't receive it from CRA until Oct 6th. CRA initially promised JBI that the report would take 1 week + 1 day. in fact it took closer to 7 weeks.
Those details being worked out include setting emission limits, testing and monitoring requirements, operational parameters if required, input restrictions and a host of other items.
The results of all of this will come out in the permit language.
Each specific detail in the permit language has both economic and operational implications for JBII. Since this is the first permit, it will set the playing field for all future permits.
That is why it is so important to take the time to get it right.
Fear, Uncertainty, and Doubt. We create it not because it's our job, but because it is our passion. Apply where needed.
