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May 16, 1977 Emissions Offset Policy-City
of Philadelphia 25.2
The emission decreases effected by the closure of the Bartrum incinerator cannot be sued to offset the emissions from the proposed new refuse-fired steam generator. Since the source was closed prior to submittal of the application for the new source, and its closure was not a result of an enforcement action providing for the new source, it cannot be sued as an emission offset.