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Environmental and Regulatory Highlights of the Fall 2019 Unified Agenda of Regulatory Actions

In late December, the Office of Management and Budget (OMB) released the “Fall 2019 Unified Agenda of Regulatory Actions” just a few days before the Calendar turned to the year 2020....more

EPA Will Soon Issue the Latest Revision to the Risk Management Program (RMP) Chemical Release Rules

On November 21, 2019, EPA released a pre-publication copy of its Reconsideration of the revised Risk Management Program (RMP) Rules....more

Trump Issues Executive Orders to Rein In Use of Guidance Documents in Enforcement Proceedings

Meant to enhance fairness and transparency in federal administrative enforcement, the new presidential EOs will significantly affect the practice of administrative law. Two recent Executive Orders will curtail use of...more

U.S. Supreme Court Oral Arguments: Maritime Charters and the Specter of a New Permitting Regime

Earlier this month, the Supreme Court heard oral arguments in two important environmental cases—one that could change the approach to routine maritime charters and another that could introduce a potentially punishing...more

Two Decisions by Federal Appeals Courts Uphold Agency Deference

Two recent decisions from federal appeals courts illustrate once again that the courts will extend significant judicial deference to federal agencies that are grappling with controversial and complicated issues subject to...more

The U.S. Court of Appeals Upholds Denial of Alternative Fuel Tax Credits and the Imposition of Large Penalties

The federal government has long encouraged the development and use of alternative fuels by enacting legislation that promises tax credits for such use....more

EPA and the Corps of Engineers Repeal the 2015 “Waters of the United States” Rule

The pre-publication version of the final rule to be promulgated by EPA and the U.S. Army Corps of Engineers (ACOE) to repeal the 2015 redefinition of the Clean Water Act’s term “Waters of the United States” which is the...more

Clean Water Act Cases: Of Irrigation and Navigability

The federal courts have recently decided two significant Clean Water Act (CWA) cases: State of Georgia, et al. v. Wheeler, where the US District Court for the Southern District of Georgia held that the 2015 rulemaking...more

A Survey of New Texas Environmental Laws

This is a brief survey of many of the environmental and regulatory laws passed by the Texas Legislature and signed by the Governor in the 86th Regular Session of the Legislature, which ended in May 2019....more

DC Circuit Issues Two Important Clean Air Act and Administrative Law Decisions

The U.S. Court of Appeals or the District of Columbia has recently issued two important rulings on the Clean Air Act in particular and administrative law in general: California Communities Against Toxics, et al., v. EPA and...more

Montana Federal Court Holds that an Interior Department’s Federal Advisory Committee Was Improperly Reestablished

On August 13, 2019, in a case that may have an impact on the leasing of federal lands for energy development in the future, the U.S. District Court for the Missoula, Montana Division, issued a ruling in the case of Western...more

DC Circuit Approves, with Some Misgivings, FERC’s Approval of the Atlantic Sunrise Natural Gas Pipeline Extension

The U.S. Court of Appeals for the DC Circuit decided the case of Allegheny Defense Project, et al. v. Federal Energy Regulatory Commission on August 2, 2019. ...more

Federal District Court Rejects Government’s Motions to Dismiss Challenges to Interior Department’s New Interpretation of MBTA

In January 2017, the outgoing Solicitor of the Department of the Interior issued a memorandum which reaffirmed the Department’s “long-standing interpretation of the Migratory Bird Treaty Act that the MBTA prohibits the...more

DC Circuit Rejects Challenge to EPA’s CERCLA Decision Regarding Hardrock Mining Industry

In a decision that will likely be welcomed by the electrical power, chemical manufacturing, and petroleum and coal products manufacturing industries, on July 19, 2019, the U.S. Court of Appeals for the District of Columbia...more

DC Circuit Upholds EPA’s Latest RCRA Recycling Rule

On July 2, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided the case of California Communities Against Toxics, et al. v. EPA. In this decision, the court rejected the latest petition to strike or...more

As the Term Winds Down, Several Important Regulatory Cases Await the U.S. Supreme Court

The Supreme Court will be deciding some very important regulatory law cases in the new few weeks as the term winds down. CERCLA Circled - Last week, the Court granted a petition to review a significant CERCLA case,...more

As Some States Use the Clean Water Act to Delay Energy Projects, EPA Issues New CWA 401 Guidance

In just the past few weeks, three states have used their Clean Water Act 401 authority to delay, for an indefinite period, FERC-authorized pipeline expansion projects....more

Recent Environmental Cases: Something in the Water, in the Air and in the Woods

State of Texas, et al. v. US EPA. The revised regulatory definition of “Waters of the U.S.” continues to generate litigation in the federal courts....more

Future Environmental Rulemaking Proceedings Listed in the Spring 2019 Unified Federal Agenda

The latest federal regulatory agenda has been released, which, among other matters, lists proposed and projected environmental regulatory proceedings being considered by different departments and agencies. ...more

Environmental Roundup – May 2019

Federal Courts of Appeal - Dam Claims Collapse - On May 7, 2019, the U.S. Court of Appeals for the Eleventh Circuit decided the case of Navelski, et al. v. International Paper Company....more

Texas Supreme Court: State Agency Actions Affirmatively Misleading People about Procedural Rights Can Be a Violation of Due...

On May 3, 2019, the Texas Supreme Court issued a significant administrative law ruling in the case of Mosely v. Texas Health and Human Services Commission. ...more

A Property Tax Exemption, Misapplied, in Texas

In an important ruling for Texas businesses, the Texas Supreme Court has unanimously ruled that the TCEQ misapplied the Texas property tax’s exemption for specified pollution control equipment....more

Environmental Roundup – April 2019

Besides showers, this April brought a number of notable new environmental decisions issued by the federal courts. ...more

EPA Announces Decision to Retain Current Position on RCRA Regulation of Oil and Gas Production Wastes

After much study, EPA has decided against changing its current RCRA Subtitle D rules affecting the state regulation of oil and gas exploration & production waste. ...more

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