On February 23, 2015, the U.S. District Court for the Middle District of Pennsylvania issued a decision finding eight compressor stations to be "separate sources" under the Clean Air Act and State of Pennsylvania regulations....more
Operating conditions during periods of startup, shutdown, and malfunction (SSM) are not normal and often result in unrepresentative emissions that exceed permitted limitations.
Originally published in The Natural Gas &...more
On October 6, 2014, EPA issued a final rule mandating the use of the 2013 standard, ASTM E1527-13, for conducting Phase I Environmental Site Assessments for satisfaction of All Appropriate Inquiries ("AAI") under CERCLA. . ...more
Evaluating environmental risks associated with real estate transactions is a standard, and often standardized, practice for sophisticated real estate practitioners. However, in light of several recent developments - the...more