Advocacy Urges Greater Time and Flexibility in Lime NESHAP Amendments

On February 9, 2024, the Environmental Protection Agency (EPA) published a proposed rule titled “National Emissions Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Amendments.” The rule supplements a 2023 proposal establishing emission standards for pollutants from lime manufacturing facilities. Advocacy filed a public comment on this rule on March 11, 2024.

Acknowledging that the proposal would have a significant impact on a substantial number of small entities, the EPA convened a Small Business Advocacy Review (SBAR) Panel which published a final report in November 2023.

Advocacy applauded the EPA for including multiple panel recommendations in the proposed amendments. Advocacy also recommended the EPA grant additional time for small businesses to comply with the proposed rule. With respect to the individual emissions standards discussed in the amendments, Advocacy supported a health-based standard for hydrogen chloride. Advocacy also suggested alterations to the EPA’s limitations on mercury and organic Hazardous Air Pollutants (oHAPS). Additionally, Advocacy does not feel the EPA has enough information to warrant its proposed standard for dioxin/furan emissions.  

For more information, please contact Assistant Chief Counsel Nick Goldstein at (202) 772-6948 or


Comment Letter – Lime Manufacturing Plants Amendments (Docket ID EPA-HQ-OAR-2017-0015) (PDF, 80 KB)