A goverment agency can not afford to exercise preferential treatment.  This 
appears to be rank discrimination if the case is as clear cut as you 
describe.  If EPA has approved procedures that apply to biodiesel production 
facilities generally,  you need to ask on what basis can they single you out 
for different and more stringent rules?   Perhaps you need to do no more than 
ask this question.   Your next step  might be to contact the Inspector 
General of EPA and ask this question.  Government agencies are usually 
particularly sensitive to charges of preferential treatment and try to avoid 
them.  This is the kind of abuse, I believe,  which the EPA Inspector General 
 would want to handle directly.  (Waste, fraud, and abuse, is their 
baliwick.)   Better yet, if you wrote a strong letter to the EPA 
Administrator, copy to your Congressman or Senator objecting to this on the 
basis of preferential treatment,  the Inspector General would  likely become 
immediately involved, and I would bet your problem would receive some prompt 
attention.  If not, the next step could be to ask  your Congressman or 
Senator to call for a Congressional hearing.     




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