In the wake of EPA’s proposed rule to force 36 states to revise their state implementation plans (SIPs) to control emissions during periods of startup, shutdown and malfunction (SSM Rule), a number of states filed comments objecting to EPA’s approach as heavy-handed and contrary to the cooperative federalism scheme of the Clean Air Act (the Act).  Claudia O’Brien and Karl Karg have written a blog entry describing the rule, the controversial rulemaking process, and the states’ main objections to the rule.