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Biden’s Science and Environmental Justice Orders Foretell a New Era of Rulemaking and Enforcement That Go Beyond Climate

Last week’s “Climate Day” actions grabbed headlines primarily for how they respond to climate risk through increased federal coordination. Equally important may be the actions the Biden administration took that day to combat...more

DOE to Review Appliance and Building Energy Efficiency Regulations

Shortly after inauguration, President Joseph R. Biden signed an Executive Order (EO) entitled “Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis.” This sweeping Executive Order...more

Closure: EPA Finalizes Long-awaited CCR Rule Revisions and Surface Impoundment Deadlines

Following years of litigation and a segmented rulemaking process, the U.S. Environmental Protection Agency (EPA) finalized revisions to portions of its coal combustion residuals (CCR) regulations governing, among other...more

House Democrats Unveil Proposal to Frame Climate Legislation in 2021

- Democrats in the House Select Committee on the Climate Crisis have released a Climate Crisis Action Plan that aims to achieve net-zero emissions throughout the United States by 2050 and “net-negative” emissions by 2100,...more

EPA May Again Update Enforcement and Cleanup Policies in Light of New COVID-19 Executive Order

President Trump issued an Executive Order on Regulatory Relief to Support Economic Recovery on May 19. Generally, the Order directs federal agencies to respond to the COVID-19 crisis by “rescinding, modifying, waiving, or...more

Supreme Court Rejects EPA’s Watered-down View of Jurisdiction over Groundwater Discharges

The U.S. Supreme Court clarified that the scope of federal protection under the Clean Water Act includes any “functional equivalent” of a direct discharge to navigable waters from a point source. The Court’s decision is the...more

EPA Stepping Off the Gas at Cleanup Sites in Response to COVID-19

On April 10, 2020, the U.S. Environmental Protection Agency’s (EPA or the Agency) Office of Land and Emergency Management and Office of Enforcement and Compliance Assurance issued Interim Guidance to EPA’s Regional Offices...more

The Phase I Environmental Site Assessment: Unexpected COVID-19 Victim?

- The COVID-19 crisis has left consultants, lenders, servicers, investors and other users struggling to assess environmental conditions of assets as they question the ability to conduct, and the utility of, phase I...more

EPA Enforcement Falls Victim to COVID-19

In response to requests for leniency as companies grapple with reduced workforces during the COVID-19 crisis, the U.S. Environmental Protection Agency (EPA) issued a temporary policy announcing that it will exercise...more

The Last Straw? Recent Actions and Outlook for Single-Use Plastics

- Weakness in the United States recycling model has been exposed by dramatic action in Asia, prompting a flurry of legislative activity at the local, state and federal level. - Proposals extend beyond food, beverage and...more

Shiny, Happy NEPA: How the Administration Plans to Make NEPA More User-Friendly

On January 10, 2020, the White House’s Council on Environmental Quality (CEQ) issued a proposed rule that would substantially revise its regulations for implementing the procedural provisions of the National Environmental...more

As Bankruptcy Bells Ring in the Outer Continental Shelf, BSEE May Toll for You

In 2014, we wrote about efforts by the U.S. Department of Interior’s Bureau of Safety and Environmental Enforcement (BSEE) to require less traditional parties to fund the decommissioning of idle oil and gas wells and related...more

Agencies Get Their Ducks in a Row on Revising Endangered Species Act Rules

Last week, final rules from the U.S. Fish and Wildlife Service and the National Marine Fisheries Service (collectively, “the Services”) impacting key components of the Endangered Species Act (ESA) were published in the...more

Supreme Court Strengthens Protection of Confidential Business Information Submitted to Federal Agencies

Food Marketing Institute v. Argus Leader Media, decided June 24, 2019 by the Supreme Court, substantially expands the Freedom of Information Act exemption for confidential business information. The ruling is significant for...more

EPA to States: Don’t Rock the Boat with Water Quality Certification Review

On June 7, 2019, the U.S. Environmental Protection Agency (EPA) issued updated guidance to “clarify and provide recommendations concerning the implementation of” Section 401 of the Clean Water Act (CWA), which could have...more

The River No Longer Runs through It: EPA to Cease Regulating Releases of Pollutants to Groundwater

After decades of insisting otherwise and before the U.S. Supreme Court has had a chance to rule on the issue, the U.S. Environmental Protection Agency (EPA) took steps to limit its interpretation of the Clean Water Act’s...more

Califormaldehyde: EPA Formally Adopts California-Like Requirements for Composite Wood Products

On March 22, 2019, the U.S. Environmental Protection Agency (EPA) will begin to implement its own formaldehyde emission standards as required under the Formaldehyde Standards for Composite Wood Products Act, Title VI to the...more

Don’t Just Investigate; Promulgate! Court Orders Chemical Safety Board to Produce Chemical Reporting Requirements

• A federal court recently ordered the CSB to promulgate final accidental chemical release reporting regulations within 12 months. • The Clean Air Act requires that those regulations be binding on all entities subject to...more

Dipping Its Toe in the Groundwater? Supreme Court Eyes Expedited Review for Clean Water Act Case

On December 3, 2018, the Supreme Court of the United States issued an order requesting the Solicitor General to weigh in on a case related to the legal status of some types of groundwater. The catch? The Court’s order comes...more

Alive, for Now: D.C. Circuit Restores Obama-era Risk Management Plan Amendments

On September 21, 2018, the U.S. Court of Appeals for the District of Columbia Circuit issued an expedited mandate to the U.S. Environmental Protection Agency (EPA), forcing the agency to reinstate several provisions of its...more

EPA Proposes Rollback to 2016 Methane Rule

On September 11, 2018, the U.S. Environmental Protection Agency (EPA) announced a proposed rule to amend various provisions of a key Obama-era regulation that sought to reduce methane emissions from oil and natural gas...more

Stay or Go: D.C. Circuit Halts EPA’s Stay of Obama-era Risk Management Plan Amendments

On August 17, 2018, the United States Court of Appeals for the District of Columbia Circuit vacated a rule that delayed the effective date of the 2017 Risk Management Program (RMP) Rule amendments issued by the U.S....more

EPA Proposes Replacement for Clean Power Plan

On Tuesday, August 21, 2018, the U.S. Environmental Protection Agency (EPA) announced its Affordable Clean Energy (ACE) Rule, a proposal to replace the Clean Power Plan issued in 2015. EPA Acting Administrator Andrew Wheeler...more

US EPA and DOT Proposal to Freeze Fuel Economy Standards for 2021-2026

On Thursday, August 2, 2018, the U.S. Department of Transportation’s National Highway Traffic Safety Administration (NHTSA) and the U.S. Environmental Protection Agency (EPA) jointly proposed a rule to freeze the fuel...more

EPA to Study Sulfur Limit Impact on Shipping

On July 30, 2018, the U.S. Environmental Protection Agency (EPA) will host a workshop to engage stakeholders in a discussion surrounding the development of a study of the economic impacts of compliance with the North American...more

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