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In Keeping With Global Trend, Youths Continue to Advance Climate Litigation in the United States in 2023

On August 14, 2023, a Montana state court issued a first-of-its-kind judgment in the United States in favor of young plaintiffs in climate litigation. The action Held v. Montana featured 16 youth plaintiffs alleging that...more

Environmental Reviews Under NEPA to Include More Thorough Consideration of Climate Change Risks

Several recent proposals impacting implementation of the National Environmental Policy Act ("NEPA") demonstrate a renewed focus on considering climate change in federal decision-making. In July, the Council on Environmental...more

The Climate Report: Third Quarter 2023

REGULATORY ISSUES & UPDATES - New CFTC Enforcement on Carbon Markets Misconduct - The U.S. CFTC publishes a rare alert soliciting tips about potential manipulation in the carbon markets and announces the formation of...more

D.C. Circuit Vacates Part of the EPA's HFCs Phasedown Rule

On June 20, 2023, the United States Court of Appeals for the District of Columbia Circuit, in Heating, Air Conditioning & Refrigeration Distributors Int'l v. Envtl. Prot. Agency, No. 21-1251, (D.C. Cir. June 20, 2023),...more

The Climate Report | Second Quarter 2023

"Green Day" in the UK - As part of its "Powering Up Britain" strategy, the UK government has published a series of documents setting out its vision for the UK's transition to net zero and the strengthening of UK energy...more

What's Old Is New Again: Anticipating and Defeating Insurer Coverage "Defenses" for Climate Change Litigation

In Short - The Situation: Commercial policyholders are increasingly being targeted by climate change lawsuits alleging that greenhouse gas emissions from their normal operations—and the alleged failure to take...more

Supreme Court Issues Wetlands Ruling in Sackett v. EPA Decision

In Short - The Development: On May 25, 2023, the United States Supreme Court issued its decision inSackett v. EPA, providing new insight into whether wetlands qualify as "waters of the United States" subject to regulation...more

The Agency Strikes Back: EPA Proposes New Emissions Limits for Fossil Fuel-Fired Power Plants

In Short - The Situation: The Environmental Protection Agency ("EPA") has issued proposed rules to limit carbon dioxide ("CO2") emissions from fossil fuel-fired power plants (the "Proposed Rules")....more

U.S. Climate Change Litigation Update: The Supreme Court Greenlights State Court Adjudication of Climate Claims

Since 2017, a laundry list of state and local governments have sued energy companies in state court seeking damages and other relief to remedy the effects of global climate change. These climate change lawsuits allege that...more

California Takes Significant Step Towards Reforming CEQA and Streamlining Infrastructure Projects

On May 19, 2023, California Governor Gavin Newsom unveiled a significant legislative package and signed an executive order aimed at reforming the California Environmental Quality Act ("CEQA") and streamlining infrastructure...more

EPA Proposes TSCA Amendments to Improve Efficiency of New Chemical Review Process

The proposal would also make per- and polyfluoroalkyl substances ("PFAS") and certain persistent, bioaccumulative, and toxic chemical substances ("PBTs") ineligible for exemptions available under the Toxic Substances Control...more

EPA Proposes New Carbon Pollution Standards for Fossil Fuel-Fired Power Plants

The Environmental Protection Agency ("EPA") is proposing stringent carbon dioxide emissions standards for coal- and gas-fired power plants....more

EPA is Seeking Comment on Potential Designations of Additional PFAS as Hazardous Substances Under CERCLA

The Advance Notice of Proposed Rulemaking ("ANPRM") addresses seven per- and polyfluoroalkyl substances ("PFAS"), including PFBS and GenX. ...more

Bureau of Land Management Publishes Proposed Rule That May Redefine the Management of Public Lands

The Bureau of Land Management ("BLM") announced a sweeping proposed rule that would change how public lands are managed by the federal government. On April 3, 2023, BLM published a proposed rule to promote the...more

EPA Proposes Stricter Mercury and Air Toxics Standards for Power Plants

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

New York Proposes Exemption From Bar to Contribution Claims for PFAS Cleanup

The proposed amendment to NY law establishes a right to contribution for cost-recovery claims for settling parties in tort actions who clean up PFAS contamination. Per- and polyfluoroalkyl substances ("PFAS") are synthetic...more

EPA Proposes Standards to Limit Certain PFAS Substances in Drinking Water

On March 14, 2023, the EPA took a step toward imposing federal limits on certain per- and polyfluoroalkyl substances in drinking water under the Safe Drinking Water Act. The United States Environmental Protection Agency...more

The Climate Report | First Quarter 2023

Incoming: Mandatory Climate Risk Disclosures in Australia - The Climate-Related Financial Disclosure Consultation Paper proposes that, commencing with the 2024/2025 financial year, large, listed entities and large...more

Louisiana Federal Court Permits Drilling for Carbon Sequestration Project

On December 26, 2022, in Air Products v. Livingston Parish, the U.S. District Court for the Middle District of Louisiana granted Air Products Blue Energy, LLC's motion for a preliminary injunction prohibiting the enforcement...more

Fourth Circuit Denies Appeal of Trump-Era Changes to NEPA; CEQ Issues Interim Guidance on Analyzing Climate Change Effects in...

In December 2022, the United States Court of Appeals for the Fourth Circuit denied an appeal by environmental groups to revive their challenge to the 2020 amendments to the Council on Environmental Quality's ("CEQ") National...more

EPA and Army Corps Promulgate New Expansive Definition of Waters of the United States

In Short - The Situation: In 2021, the Biden Administration signaled its intent to replace the 2020 "Navigable Waters Protection Rule," which was vacated by a federal court, with a new definition of "waters of the United...more

EPA Proposes Tougher Air Quality Standards for Soot Pollution

The Environmental Protection Agency ("EPA") has announced a proposal to reduce the maximum levels of fine particle emissions....more

FTC Requests Public Comment on Potential Green Guides Updates

The Federal Trade Commission ("FTC") is soliciting comments regarding the efficiency, costs, benefits, and regulatory impact of its Guides for the Use of Environmental Marketing Claims ("Green Guides")....more

EPA Issues Guidance Addressing Discharges of PFAS

In Short - The Situation: The Environmental Protection Agency's ("EPA") new guidance memorandum to states provides direction on how they can use the National Pollutant Discharge Elimination System ("NPDES") permitting...more

EPA Proposes More Stringent Reporting of PFAS Data to the Toxics Release Inventory

On December 5, 2022, the Environmental Protection Agency ("EPA") proposed a new rule that would increase reporting obligations for per- and polyfluoroalkyl substances ("PFAS") to the Toxics Release Inventory ("TRI"). PFAS are...more

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