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Functional Interdependence

Is The “Functional Interdependence” Test Dead?

by K&L Gates LLP on

On May 30, 2014, the United States Court of Appeals for the D.C. Circuit vacated the Environmental Protection Agency’s (“EPA’s”) attempt to preserve an expansive view of what constitutes a single source of air emissions under...more

Natural Gas & Electricity Interdependency Update: FERC’s Third Quarterly Report on Gas-Electric Coordination

by Moore & Van Allen PLLC on

Pursuant to the Federal Energy Regulatory Commission (“FERC”) November 15, 2012 Order Directing Further Conferences and Reports, the FERC Staff issued its third Gas-Electric Coordination Quarterly Report to the Commission ...more

EPA Will Continue to Apply the "Functional Interdependence" Test for Air Quality Source Determinations Outside of the Sixth...

by K&L Gates LLP on

Introduction - On December 21, 2012, the U.S. Environmental Protection Agency (“EPA”) issued a new guidance memorandum (the “Page Memorandum”) on single source determinations for the oil and gas industry under the Clean...more

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