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D.C. Circuit Court Limits EPA’s Sham Recycling Rule

The United States Court of Appeals for the District of Columbia Circuit recently rejected portions of an EPA rule designed to distinguish true recycling from “sham recycling” under the Resource Conservation and Recovery Act...more

Environmental Notes - July 2017

On June 1, 2017, President Trump announced that the United States will withdraw from the Paris climate agreement (“Paris Agreement”). The Paris Agreement was signed by 195 countries in December of 2015. The goal of the...more

United States Withdraws From Paris Climate Agreement

On June 1, 2017, President Trump announced that the United States will withdraw from the Paris climate agreement (“Paris Agreement”). The Paris Agreement was signed by 195 countries in December of 2015. ...more

Environmental Notes - May 2017

The Clean Power Plan (“CPP”), and its companion new source review rule, is the Obama Administration’s signature regulation on reducing greenhouse gas emissions from power plants. Among other things, it requires states to put...more

Trump Orders Federal Agencies to Reconsider Energy and Climate Change Initiatives

President Trump signed an executive order on March 28, 2017 that will have a significant impact on existing energy and environmental policies and regulations. Entitled “Promoting Energy Independence and Economic Growth,” the...more

Environmental Notes - April 2017

Most industrial facilities will, at some point, be inspected by an environmental regulatory agency. Generally, regulatory agencies have authority to enter public or private property that is governed by an environmental...more

Successfully Managing Environmental Regulatory Inspections

Most industrial facilities will, at some point, be inspected by an environmental regulatory agency. Generally, regulatory agencies have authority to enter public or private property that is governed by an environmental...more

Environmental Notes - December 2016

The Virginia Department of Environmental Quality (“DEQ”) has clarified its approach to issuing “no further action” letters (“NFAs”) for sites with both petroleum and non-petroleum contamination. This clarified approach will...more

EPA Finalizes Change to Area Source Boiler Rule

EPA has revised the National Emissions Standards for Hazardous Air Pollutants (NESHAP) for industrial, commercial and institutional boilers at area sources. The area source boiler NESHAP was initially promulgated on March...more

Environmental Notes - November 2016

EPA has revised its procedures for making certain changes to its “Test Methods for Evaluating Solid Waste, Physical/Chemical Methods,” also known as SW-846. The test method and its compendium of guidance documents provide...more

EPA Proposes Revisions to PSD and Title V Greenhouse Gas Permitting Regulations

EPA recently proposed revisions to its Prevention of Significant Deterioration (“PSD”) and Title V regulations that will impact the permitting of greenhouse gases (“GHGs”). These regulatory changes are being proposed to...more

Smart Document Control: Know When To Hold ‘Em, Know When To Fold ‘Em

In many ways a smart document control policy is like the lyrics in a Kenny Rogers song: “You’ve got to know when to hold ‘em, know when to fold ‘em.” Almost all environmental statutes and regulations require that certain...more

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