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Re: the big guy post# 77291

Wednesday, 11/17/2010 9:43:35 PM

Wednesday, November 17, 2010 9:43:35 PM

Post# of 312015

If you are trying to tell this board that they can immediately set up shop with a P2O processor on the blending site I would say that you are dead wrong. I would ask for proof. THe purpose of permitting is to control pollution. THere is no way you can change the basic product or output and use the same permit. It may be a modification or change to an existing permit, but the process is the same... testing etc, as has been done in NY.

Conversely, if you are indeed correct, than JBI has wasted an incredible amount of time and money on the whole NY setup.

Either way.. hardly a victory or good news..



That is a fair statement, and I agree with most of it. I certainly don't think an existing "Certificate of Approval for Air" would necessarily entitle a company to utilize the certificate (permit) for operating a new manufacturing process on the premises. If the permit doesn't cover P2O operations, then you are likely correct that the company would need either a new permit or a modification/amendment to the existing permit in order to commence operations, unless perhaps the modification falls within an exemption. I don't think we can really say for sure at this point what is required since we do not know the terms of the October 15, 2010, Certificate of Approval. The 10Q did not indicate whether or not the current permit can be used in connection with P2O operations at the blending site.

I do think this is very good news though. The more permits the company has in place, the less room there will be for further delays down the road. I also think that modifications or amendments to existing permits will be faster and easier to obtain than acquiring the permit in the first place. I am interested in seeing how this develops.