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President Trump Invokes National Security to Delay Mercury and Air Toxics Standards

President Donald Trump's April 8, 2025, proclamation extends the compliance deadline for the EPA's Mercury and Air Toxics Standards (MATS) by two years, from July 8, 2027 to July 8, 2029, asserting national security concerns...more

President Trump Issues Executive Order Targeting State Climate Programs

President Donald Trump on April 9, 2025, issued an executive order (EO) titled "Protecting American Energy from State Overreach." The EO aims at "unleashing American energy" by removing legal restrictions imposed by state...more

Clean Air Act Rulemakings Don't Follow the Normal Rules – Just Ask the Supreme Court

Every law student learns that the Administrative Procedure Act (APA) outlines the default rules for how federal agencies propose and finalize regulations and how courts review them. But for many significant actions under the...more

The Impact of a Trump EPA on California's Mobile Source Rules

Under Clean Air Act (CAA) Section 209(a) (42 U.S.C. § 7543), states are preempted from adopting or enforcing emissions standards for new motor vehicles or new motor vehicle engines. However, because California had adopted its...more

2023 PFAS Year in Review: EPA Policy and Aqueous Film-Forming Foam Litigation Updates

2023 was a busy year for folks following legal developments related to per- and polyfluoroalkyl substances (PFAS). In December, the U.S. Environmental Protection Agency (EPA) issued its Second Annual Progress Report. Some of...more

California Mandates Greenhouse Gas Emissions Disclosures Beginning Jan. 1, 2024

Assembly Bill 1305 (AB 1305), also called the Voluntary Market Disclosures Act, is a new California statute requiring companies to make certain disclosures if they make claims in the state regarding greenhouse gas (GHG)...more

EPA Publishes Comprehensive PFAS Reporting Rule Under TSCA

The U.S. Environmental Protection Agency (EPA) published a far-reaching and enormously important final rule (Rule) on Oct. 11, 2023, requiring comprehensive reporting of per- and polyfluoroalkyl substances (PFAS) manufactured...more

The Rubber Meets the Road with California's Green Chemistry Law

What do nail polish, children's foam-padded sleeping mats and tires have in common? Not much at first glance, but all have been identified as "priority products" under California's Safer Consumer Products regulations...more

Answers to 4 Major Questions: EPA Proposes Power Plant GHG Rule After West Virginia v. EPA

The U.S. Environmental Protection Agency (EPA or Agency) on May 23, 2023, published a new suite of proposed standards for coal- and gas-fired power plants that will limit greenhouse gas (GHG) emissions. The proposed rule...more

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