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Chris Harris - 2013 Conference Speaker
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The Regulatory Future of Off-Spec Used Oil

Presented by Chris Harris
NORA General Counsel

Does the phrase "non-harzardous secondary materials" mean anything to you? As you probably already know, NHSM is EPA-speak for fuels that the Agency believes should be incinerated rather than burned for energy recovery. NORA became involved several years ago when EPA targeted off-spec used oil fuel.  NORA has actively participated in the seemingly endless rule-making and (along with other trade associations) sued EPA, asserting that the EPA's rule was arbitrary and capricious.  Now that the rule is final, what is the future of off-spec used oil? Will NORA's petition to EPA be granted? Is the litigation over? What are the intriguing side-issues that are unresolved by the final rule? NORA's General Counsel, Chris Harris, who has been manning the NHSM battle station since the beginning of this controversy, will answer these questions and any others that you send his way.

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