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Spotlight on PFAS and Other Substances in Cosmetics Likely to Grow in 2022

This year – 2022 – may finally be the year that the effort to modernize safety standards in the U.S. for cosmetics and other personal care products, which has been ongoing since 2013, comes to fruition. If so, the new...more

EPA’s PFAS Strategic Roadmap Sets Broad and Ambitious Goals

Near- and Longer-Term Objectives Expected to Impact Wide Range of Industries - On October 18, 2021, the Environmental Protection Agency (EPA) released its PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024. For...more

US EPA Issues Draft Strategic Plan

Emphasis on Environmental Justice and Climate Change - The EPA's draft Strategic Plan provides the key to understanding the agency's priority goals and initiatives, including Climate Change and Environmental Justice...more

California Proposes Designating PFOA as a Carcinogen under Proposition 65

Designation of PFOA as a Carcinogen Will Increase Litigation Risks and Expand Proposition 65 Labeling Obligations - On March 19, 2021, California’s Office of Environmental Health Hazard Assessment (OEHHA) announced that...more

Federal Court Vacates Key Clean Water Act Nationwide Permit

U.S. Army Corps of Engineers Enjoined from Using NWP 12 to Authorize “Utility Line Activities” in Jurisdictional Waters - On April 15, 2020, a federal district court in Montana invalidated the United States Army Corps of...more

Energy Newsletter - December 2019

Rekindling the Flame: Oil & Gas Securitizations - A number of recent structurings of investment-grade rated securitizations of oil and gas wells are sparking conversations in the U.S. upstream oil and gas industry about...more

Dark Waters and the Future of PFAS Laws

The newly-released movie Dark Waters, starring A-list actors Mark Ruffalo and Anne Hathaway, has increased public attention on a group of emerging chemicals called Per- and Polyfluoroalkyl substances (“PFAS”). This increased...more

Energy Newsletter - November 2019

The IMO and the Price of Gas or The Impact of the International Maritime Organisation’s Sulphur 2020 Limit for Marine Fuel Oil on the Price of Gas - The main bunker fuel for ships is High Sulphur Fuel Oil (HSFO, with...more

EPA Repeals WOTUS Rule

On Tuesday, October 22, 2019, the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers published a final rule repealing the Obama Administration’s 2015 “WOTUS” rule, which set new and more expansive...more

Energy Newsletter - March 2019

Texas Supreme Court Finds Anadarko is Entitled to Over $100 Million in Deepwater Horizon Defense Costs Based on Undefined Term in Insurance Policy - Insurance coverage litigation arising out of the 2010 Deepwater Horizon...more

Supreme Court and EPA to Address Broad Expansion of Clean Water Act Liability by Lower Courts

The scope of the Clean Water Act (“CWA”) has vexed the courts and lead agencies for over a decade. In one of the most significant environmental cases this year, on February 19, 2019, the Supreme Court granted the petition for...more

EPA Issues New Waste Rules for Hospitals, Medical Clinics and Pharmacies

The U.S. Environmental Protection Agency (“EPA”) recently issued new regulations for managing pharmaceutical waste under the Resource Conservation and Recovery Act (“RCRA”). The rules specify new requirements for hazardous...more

EPA Announces First-Ever Comprehensive Nationwide PFAS Action Plan

On February 14, 2019, the United States Environmental Protection Agency (“EPA”) published its long-awaited “action plan” intended to address potential risks posed by Per- and Polyfluoroalkyl substances (“PFAS”). PFAS are a...more

Energy Newsletter - January 2019

Clean Water Agencies Propose to Redefine and Limit “Waters of the United States” - The United States EPA and the United States Army Corps of Engineers are proposing to redefine—and significantly limit—the scope of “Waters...more

Clean Water Agencies Propose to Redefine and Limit “Waters of the United States”

The United States EPA and the United States Army Corps of Engineers are proposing to redefine—and significantly limit—the scope of “Waters of the United States” (“WOTUS”) that are subject to federal jurisdiction under the...more

Energy Newsletter - September 2018

A Texas Federal Judge Turns Up the Heat on Oil Companies Facing Climate Change-Related Securities Class Actions - On August 14, 2018, the United States District Court for the Northern District of Texas issued a...more

Updates to EPA’s Risk Management Program Immediately Effective After D.C. Circuit Issues Unexpected Early Mandate

On Friday, August 31, 2018, the U.S. Court of Appeals for the District of Columbia unexpectedly granted a request to issue its mandate expeditiously following its decision regarding the U.S. Environmental Protection Agency’s...more

D.C. Circuit Vacates Risk Management Program Delay Rule

On August 17, 2018, the U.S. Court of Appeals for the District of Columbia vacated an Environmental Protection Agency (“EPA”)rule delaying the effective date of the Obama administration’s final rule updating EPA’s Risk...more

WOTUS Rule Now Applies in 26 States After Court Enjoins Suspension Rule

Injecting yet more confusion into the ongoing saga of the Waters of the United States (“WOTUS”) Rule, on August 16, 2018, the United States District Court for the District of South Carolina enjoined the WOTUS “Suspension...more

Clean Water Act Agencies Solicit Comments to Support Repeal of WOTUS Rule

On July 12, 2018, the United States Environmental Protection Agency (“USEPA”) and the United States Army Corps of Engineers (“USACE”) published a “Supplemental Notice of Proposed Rulemaking” soliciting additional comments on...more

Energy Newsletter - May 2018

Courts Hold Clean Water Act Regulates Discharges through Groundwater, as Congress and Regulators Consider Responses - The Ninth Circuit and Fourth Circuit have joined a growing number of lower courts finding that the...more

Courts Hold Clean Water Act Regulates Discharges through Groundwater, as Congress and Regulators Consider Responses

The Ninth Circuit and Fourth Circuit have joined a growing number of lower courts finding that the Clean Water Act (“CWA” or the “Act”) regulates discharges to groundwater that serves as a conduit between a point source and...more

Fourth Circuit Expands Citizen Suits Under the Clean Water Act; Finds Potential Liability for Discharges Through Groundwater

A recent 2-1 decision from the Fourth Circuit has expanded potential liability under the Clean Water Act (“CWA” or the “Act”): — The Fourth Circuit became the second appellate court in as many months to adopt the “conduit”...more

Energy Newsletter - March 2018

Good news at last for the development of offshore wind projects in France - While France had launched in 2011 a very ambitious offshore wind farm development program, aiming to reach 6 GMW of wind turbine installations at...more

As Ninth Circuit Expands Clean Water Act Liability for Groundwater Discharges, EPA Seeks Comment on Clean Water Act Coverage

A recent Ninth Circuit decision has expanded Clean Water Act (“CWA” or the “Act”) liability, holding that discharges to groundwater are actionable if there is a “fairly traceable” connection between the groundwater discharge...more

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