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EPA's Proposed Rule Signals Rollback of Chemical Safety Requirements as Key Questions Remain

The Risk Management Program (RMP) regulations under Section 112(r) of the Clean Air Act (CAA) require facilities using certain toxic or flammable substances to develop and submit a risk management plan to the U.S....more

SEC Initiates Review of ESG Fund Names Rule

The U.S. Securities and Exchange Commission (SEC) adopted Rule 35d-1 under the Investment Company Act of 1940 regarding Investment Company Names (the Names Rule) in 2001 to prevent fund names from being materially deceptive...more

The Latest Pandora's Box: What You Need to Know Now About State EPR Laws

Since Holland & Knight's previous alert about state extended producer responsibility (EPR) laws for packaging, there have been significant developments in the implementation of these programs. Seven states currently have EPR...more

EPA's PFAS CERCLA Designation and Its Impact on EPA Brownfields Grant Funding

The U.S. Environmental Protection Agency (EPA) on April 17, 2024, announced the designation of two per- and polyfluoroalkyl substances (PFAS) – perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) – as...more

EPA Adopts New Enforcement Approach Prioritizing Compliance Assistance and Communication

Craig Pritzlaff, Acting Assistant Administrator of the U.S. Environmental Protection Agency (EPA) Office of Enforcement and Compliance Assurance (OECA), transmitted a memorandum (Pritzlaff Memorandum) on Dec. 5, 2025, to OECA...more

Reversing Course for Endangered Species Act: Administration Proposes ESA Regulatory Amendments

The U.S. Fish and Wildlife Service (FWS) published four proposed rules in the Federal Register on Nov. 21, 2025 – two of which are jointly proposed by the National Marine Fisheries Service (NMFS) – that aim to restore much of...more

The Last Wave: EPA and Army Corps Seek to Conform WOTUS Definition to Sackett

The U.S. Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers on Nov. 17, 2025, announced the release of a proposed rule revising the definition of "waters of the United States" (Proposed WOTUS Rule). The...more

Permitting Reform in Action: CEQ Updates Roadmap for Agency NEPA Compliance

In keeping with the Trump Administration's goals of permitting reform, the Council on Environmental Quality (CEQ) on Sept. 29, 2025, issued an updated guidance memorandum to the heads of federal agencies regarding...more

New Executive Action Aims to Streamline Environmental Reviews Through Digital Modernization

The Trump Administration has issued a Presidential Memorandum, "Updating Permitting Technology for the 21st Century," aimed at modernizing and streamlining the federal environmental review and permitting processes through...more

Interior Department Streamlines Oil and Gas Leasing Process on Public Lands

In a significant policy shift, the U.S. Department of the Interior announced a Bureau of Land Management (BLM) policy update designed to expedite the oil and gas leasing process on public lands. Through a newly issued...more

DOI Implements Unprecedented 14-Day NEPA Review Process Under National Energy Emergency EO

In a significant move to accelerate domestic energy development, the U.S. Department of the Interior (DOI) has announced emergency permitting procedures that will dramatically compress environmental review timelines. Under...more

New York Proposes SEQRA Amendments to Implement Environmental Justice Siting Law Provisions

While the Trump Administration has rolled back federal environmental justice initiatives and taken efforts toward expediting federal environmental review processes, the New York State Department of Environmental Conservation...more

Seismic Changes in Federal Environmental Reviews: CEQ to Rescind NEPA Regulations

The Council on Environmental Quality (CEQ) has issued an interim final rule and corresponding memorandum to heads of federal departments and agencies indicating its intent to rescind prior National Environmental Policy Act...more

Court's Denial of Review Leaves Open Questions of CEQ Authority

The U.S. Court of Appeals for the District of Columbia Circuit on Jan. 31, 2025, declined a request to review its decision that challenged the authority of the Council for Environmental Quality (CEQ), leaving open questions...more

Potential Implications of President Trump's Wind Energy EO on Offshore Leasing, Development

This Holland & Knight alert provides a summary of President Donald Trump's Wind Energy EO, an overview of the offshore wind leasing process and considerations for current lessees regarding potential outcomes and legal...more

Impacts of a Trump EPA on Chemical Transporters' Reliance on In-Transit Exemptions

The global bulk chemical shipping industry relies on chemical transportation depots to be responsive to market demands by temporarily holding trailers and containers of chemical products en route to their final destinations...more

Understanding President Joe Biden's Offshore Drilling Restrictions

In his final days in office, President Joe Biden has exercised his executive authority to withdraw more than 625 million acres of federal waters from future oil and gas leasing – the largest withdrawal of its kind in U.S....more

Adding Fuel to the Fires Calling for Permitting Reform

In a surprise decision likely to add further fuel to the fires calling for permitting reform and uncertainty to the environmental review process for federal funding and approval, the U.S. Court of Appeals for the District of...more

EPA Imposes More Stringent Lead Paint Dust Requirements

In response to a decision by the U.S. Court of Appeals for the Ninth Circuit finding that the U.S. Environmental Protection Agency's (EPA) updates to its lead paint hazard standards were deficient because they improperly took...more

Are You Tracking Your Packaging Data Yet?

Extended Producer Responsibility (EPR) laws represent a pivotal shift in environmental and sustainability compliance, placing the onus of end-of-life product management on Producers, the parties that produce the products...more

Court Strikes Down Key Endangered Species Act Opinion

A federal court has thrown out key Endangered Species Act (ESA) analyses of oil and gas operations in the Gulf of Mexico, which will be vacated as of Dec. 20, 2024. The United States District Court for the District of...more

Council on Environmental Quality Substantially Rewrites NEPA Regulations

The Council on Environmental Quality (CEQ) on May 1, 2024, published its Phase II regulations1 under the National Environmental Policy Act (NEPA).2 As part of a multiphase effort to amend the NEPA regulations that straddled...more

U.S. Supreme Court May Soon Discard or Modify Chevron Deference

For nearly 40 years and in more than 18,000 judicial opinions, federal courts have used the Chevron doctrine to defer to an agency's reasonable interpretation of an ambiguous statute. Under the doctrine, named for the 1984...more

Chemical Transporters Face Ongoing Challenges from EPA's Focus on "Transit-Related" Activity

Chemical transport, tank cleaning and transportation depot operators breathed a sigh of relief in March 2024 when the U.S. Environmental Protection Agency (EPA) dropped provisions from a proposed rule when it issued its final...more

Safe Harbor Policy Bolsters Case for Strong Environmental Due Diligence in M&A Transactions

The U.S. Department of Justice (DOJ) in October delivered a clear message to companies involved in mergers and acquisitions (M&A) and their advisers: Acquiring companies will not be penalized for timely voluntary disclosure...more

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