Baltimore Clean Air Act Lawsuit Files

	A	B	C	E
1	Date Filed	#	Document

2	4/30/2019	1	Complaint	Bold items are the key documents.
3			Civil Cover Sheet	Plaintiff (industry) filings are shaded in beige.
4			Exhibit A - Baltimore Clean Air Act	Defendant (city) filings are in light green.
5			Exhibit B - Wheelabrator Title V permit	Filings from the court are in grey.
6			Exhibit C - MDE Letter to EPA Submitting Maryland’s State Implementation Program (SIP)	Amicus filings from the "Local Government Coalition for Renewable Energy" (local governments with trash incinerators) are in pink
7			Exhibit D - Curtis Bay Energy Title V permit	Energy Justice Network is in blue.
8			Exhibit E - Baltimore DPW Memorandum to Baltimore City Council, dated January 28, 2019
9			Exhibit F - Baltimore DPW Fiscal Analysis of Possible Impacts of City Council Bill 18-0306, dated February 2019
10			Exhibit G - Wheelabrator Baltimore’s Refuse Disposal Permit (No. 2016-WTE-0030)
11			Exhibit H - Curtis Bay’s Refuse Disposal Permit (No. 2017-WMI-0036)
12			Summons
13	4/30/2019	2	Summons
14	5/1/2019	3	Disclosure Statement - Curtis Bay Energy
15	5/1/2019	4	Disclosure Statement - Wheelabrator Baltimore
16	5/1/2019	5	Disclosure Statement - Energy Recovery Council
17	5/1/2019	6	Disclosure Statement - National Waste and Recycling Association
18	5/1/2019	7	Disclosure Statement - TMS Hauling
19	5/6/2019	8	Summons Return Executed
20	5/6/2019	9	Motion for Admission Pro Hac Vice - James B. Slaughter, Atty for Wheelabrator and Energy Recovery Council
21	5/6/2019	10	Motion for Admission Pro Hac Vice - David Friedland, Atty for Wheelabrator and Energy Recovery Council
22	5/6/2019	11	Motion for Admission Pro Hac Vice - Joshua H. Van Eaton, Atty for Wheelabrator and Energy Recovery Council
23	5/6/2019	12	Motion for Admission Pro Hac Vice - Meghan L. Morgan, Atty for Wheelabrator and Energy Recovery Council
24	5/10/2019	13	Order on Motion to Appear Pro Hac Vice
25	5/10/2019	14	Order on Motion to Appear Pro Hac Vice
26	5/10/2019	15	Order on Motion to Appear Pro Hac Vice
27	5/10/2019	16	Order on Motion to Appear Pro Hac Vice
28	5/16/2019	17	Notice of Appearance
29	5/16/2019	18	Motion to Extend Time
30			Text of Proposed Order
31	5/16/2019	19	Order on Motion to Extend Time
32	7/15/2019	20	Request for Conference
33	7/17/2019	21	Notice of Appearance for City
34	7/17/2019	22	QC Notice - Miscellaneous
35	7/18/2019		Telephone Conference
36	7/18/2019	23	Order
37	7/18/2019	24	Order Referring Case to Magistrate Judge
38	7/19/2019	25	Status Report
39	7/22/2019	26	Order
40	7/22/2019	27	Notice of Appearance for city
41	7/22/2019	28	Order
42	7/22/2019	29	Notice of Appearance for city
43	7/22/2019	30	Motion to Dismiss for Failure to State a Claim
44			Memo in Support
45			Exhibit
46			Text of Proposed Order
47	7/23/2019	31	City proposed briefing schedule
48	7/24/2019	32	Order (schedule)
49	8/2/2019		Add and Terminate Judges
50	8/6/2019	33	Transcript (not available)
51	8/16/2019	34	Memo in Opposition to Motion to Dismiss
52			Exhibit A (Wheelabrator's permit limits)
53			Exhibit B (Curtis Bay Energy's permit limits)
54	8/23/2019	35	Motion for Partial Summary Judgment
55			Memo
56			Exhibit A - Baltimore County’s 1982 Subdivision User Contract, dated November 3, 1982
57			Exhibit B - Wheelabrator Baltimore’s Title V permit, dated April 1, 2014
58			Exhibit C - Wheelabrator Baltimore’s Waste Disposal Agreement, dated June 22, 2011
59			Exhibit D - Baltimore City’s 2011 Subdivision User Contract, dated June 22, 2011
60			Exhibit E - Baltimore City’s Solid Waste Management Plan for 2013-2023
61			Exhibit F - Curtis Bay’s Title V permit, dated May 1, 2019
62			Exhibit G - Table 1, Emission Limits Applicable to Wheelabrator Baltimore
63			Exhibit H - Table 2, Emission Limits Applicable to Curtis Bay
64			Exhibit I - Baltimore City Council Resolution 17-0034R (NOx)
65			Exhibit J - Baltimore City Council Resolution 18-0101R (NOx)
66			Exhibit K - Memorandum Regarding City Council Bill 09-0400, City of Baltimore Department of Law, dated December 9, 2009
67			Exhibit L - Wheelabrator Baltimore’s Refuse Disposal Permit, dated March 3, 2017
68			Exhibit M - Curtis Bay’s Refuse Disposal Permit, dated June 13, 2017
69			Exhibit N - Baltimore City’s DPW Memorandum to Baltimore City Council, dated January 28, 2019
70			Exhibit O - Baltimore City’s DPW Fiscal Analysis of Possible Impacts of City Council Bill 18-0306, dated February 2019
71			Exhibit P - Baltimore City Health Code §8-110, et seq.
72	8/30/2019	36	Local Government Coalition for Renewable Energy - Amicus Curiae brief
73			Motion for leave to file Amicus Curiae
74	9/13/2019	37	City Opposition to Amicus filing of Local Government Coalition for Renewable Energy
75	9/20/2019	38	Reply Memo in Support of City's Motion to Dismiss
76	10/15/2019	39	City's Cross-motion for Partial Summary Judgment and Opposition to Plaintiffs' Motion for Partial Summary Judgment
77			Exhibit A - J.B. Kitto, Jr., et al., World Class Technology for the Newest Waste-to-Energy Plant in the United States – Palm Beach Renewable Energy Facility No. 2 (Dec. 13, 2016)
78			Exhibit B - MDE Air Quality Control Advisory Council – Agenda, Minutes, and Exhibits (Dec. 11, 2017)
79			Exhibit C-1 - MDE Technical Support Document for Amendments to COMAR 26.11.08 – Control of Incinerators (Aug. 14, 2018)
80			Exhibit C-2 - "White Paper on Control Technologies and OTC State Regulations for Nitrogen Oxides (NOx) Emissions from Eight Source Categories," Stationary Area Sources Committee, 2/10/2017
81			Exhibit C-3 - Motion by Energy Answers Baltimore, LLC, to Amend the Construction Commencement Deadline in its Certificate of Public Convenience and Necessity, Supplemental Environmental Review Document DRAFT, June 2012
82			Exhibit D - Md. Register 45:17 (Aug. 17, 2018)
83			Exhibit E - MDE Response to Comments related to Amendments to COMAR 26.11.01 et seq. (Sept. 21, 2018)
84			Exhibit F - Md. Register 45:24 (Nov. 26, 2018)
85			Exhibit G - MDE NOx Reasonably Available Control Technology State Implementation Plan (July 2, 2018)
86			Exhibit H - U.S. EPA "Mercury CEMS and Sorbent Trap System Certification Under New Rules" (Jan. 29, 2015)
87			Exhibit I - Dr. Nenad Sarunac, "Evaluation and Comparison of U.S. and EU Reference Methods for Measurement of Mercury, Heavy Metals, PM2.5 and PM10 Emissions from Fossil-Fired Power Plants" (Executive Summary) (Feb. 2007).
88			Exhibit J - U.S. EPA Environmental Technology Verification Program – Dioxin Emission Monitoring Systems (Feb. 2007)
89			Exhibit K - MDE Air Quality Control Advisory Council
90			Exhibit L - Todd R. Chason, Gordon Feinblatt LLC
91			Exhibit M - State Ethics Commission – Employer List (Nov. 15, 2018)
92	10/22/2019	40	Energy Justice Network - Amicus Curiae brief
93			Motion for leave to file Amicus Curiae
94	10/22/2019	41	Disclosure Statement - Energy Justice Network
95	10/31/2019	43	QC Notice - Miscellaneous (the industry lawyers filed incorrectly and had to refile, which is why there's no #42)
96	10/31/2019	44	Reply in Support of Plaintiffs' Motion for Partial Summary Judgment and Opposition to Defendant's Cross-Motion for Partial Summary Judgment
97			Exhibit Q - Declaration of Timothy Porter
98			Exhibit R - Palm Beach Renewable Energy Facility’s Title V permit, dated January 30, 2019
99			Exhibit S: Palm Beach Renewable Energy Facility’s Final Air Construction Permit, dated November 8, 2018
100			Exhibit T: City of Baltimore, Department of Public Works, Memorandum to Baltimore City Council dated January 28, 2019 [this document was previously designated as Plaintiffs’ MSJ Exhibit N, but the document itself was inadvertently omitted from Plaintiffs’ prior ECF submission on August 23, 2019]