The United States Environmental Protection Agency (“EPA”) issued a pre-publication version of a proposed rule that would remove affirmative defense provisions from certain Clean Air Act New Source Performance Standards...more
In the first half of 2024, EPA has finalized a host of rules driven, at least in part, by concerns about disparate impacts and environmental justice. For instance, in conjunction with an April rule targeting greenhouse...more
On April 25, 2024, the Environmental Protection Agency (EPA) signed four final rules representing multi-media regulation (air, water, waste, climate) for the utility sector. Individually, each rule would have been notable for...more
The United States Environmental Protection Agency (“EPA”) issued a final denial of a petition requesting removal of the Stationary Combustion Turbines source categories from the list of categories of major sources of Clean...more
The rule, covering 218 organic chemical and polymer manufacturing plants, imposes stringent emission limits on six chemicals without exemptions for startup, shutdown, and malfunction. On April 9, 2024, the US...more
Our Environment, Land Use & Natural Resources Group reviews the Environmental Protection Agency’s announcement of final amendments to the air toxics standards for ethylene oxide (EtO) commercial sterilizers....more
The Environmental Protection Agency on March 14 announced final amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) applicable to 90 large commercial sterilization facilities that use ethylene...more
The United States Environmental Protection Agency (“EPA”) has issued a prepublication final rule addressing Clean Air Act National Emissions Standard for Hazardous Air Pollutants (“NESHAP”) for gasoline distribution...more
Several environmental organizations filed a document before the United States Environmental Protection Agency styled: Petition to Object to the Title V Operating Permit for the Delaware City Refinery (“Petition”)...more
The United States Environmental Protection Agency (“EPA”) proposed revisions to the General Provisions of the Clean Air Act National Emission Standards for Hazardous Air Pollutants (“NESHAP”). The proposed rule revises...more
The United States Environmental Protection Agency (“EPA”) published in the September 13th Federal Register a proposed rule that would amend the general provisions for Clean Air Act National Emission Standards for Hazardous...more
Louisiana has been at the center of the Biden Administration’s prioritization of environmental justice (EJ) issues. In United States v. Denka Performance Elastomer, the Eastern District of Louisiana granted a motion by the...more
The American Chemistry Council, American Fuel & Petrochemical Manufacturers, U.S. Tire Manufacturers Association, and Vinyl Institute (collectively “ACC”) submitted July 7th comments to the United States Environmental...more
The National Association of Clean Air Agencies (“NACAA”) submitted June 22nd comments to the United States Environmental Protection Agency (“EPA”) in its docket addressing Proposed National Emission Standards for Hazardous...more
A combined 82 Senators and Members of the United States House of Representatives sent a May 22nd letter to United States Environmental Protection Agency Administrator Michael Regan addressing certain aspects of EPA’s proposed...more
The United States Environmental Protection Agency (“EPA”) has issued a prepublication proposed rule addressing the Clean Air Act National Emission Standards for Hazardous Air Pollutants (“NESHAP”) for the plywood and...more
After years of delays – largely due to the COVID-19 pandemic – on April 11, 2023, the U.S. Environmental Protection Agency finally issued two proposals that would reduce ethylene oxide (EtO) emissions affecting fence-line...more
The onslaught of environmental justice-related reforms has continued in early 2023. Below, we will outline four issues to keep an eye on in the coming quarter....more
The Environmental Protection Agency ("EPA") has announced a new proposed rule that would strengthen the National Emission Standards for Hazardous Air Pollutants ("NESHAP") for Coal- and Oil- Fired Electric Utility Steam...more
EPA recently revised the national emission standard for hazardous air pollutants for certain coating manufacturers. The result is new performance tests and controls for existing affected sources adding metal hazardous air...more
EPA’s Big Plans for 2023: Top Air Rulemakings We Are Watching - An environmental lawyer walks into a cocktail party. An often-asked question is: What is happening at EPA in your world? What should we be watching that...more
The United States Environmental Protection Agency (“EPA”) and City Water, Light and Power of Springfield, Illinois (“CWL&P”) entered into an October 28th Consent Agreement and Final Order (“CAFO”) addressing alleged...more
In a recent “Enforcement Alert,” EPA set out its intent to target owners and operators of stationary engines for compliance with Clean Air Act emissions requirements. According to the Enforcement Alert, “EPA has been...more
The Energy Marketers of America (“EMA”) submitted September 13th comments on the United States Environmental Protection Agency’s (“EPA”) proposed rule addressing Clean Air Act National Emission Standards for Hazardous Air...more
The U.S. Environmental Protection Agency (“EPA”) has announced its latest priority for Clean Air Act enforcement: stationary engines. In an enforcement alert, EPA states that it has been finding numerous violations of Clean...more