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New CEQ Guidance Promotes “Responsible Deployment” of Carbon Capture, Utilization and Sequestration

Hot on the heels of a new Biden administration initiative to cut industrial sector emissions via carbon capture, utilization and sequestration (CCUS) and other methods, the Council on Environmental Quality (CEQ) issued new...more

EPA Reverses Trump Era Clean Air Act SSM Policy

The Environmental Protection Agency’s (“EPA’s”) guidance, issued Sept. 30, 2021, revoking the Trump-era Startup, Shutdown, and Malfunction (“SSM”) guidance signals difficult permitting decisions ahead for emitters across...more

Clean Air Act in Court: Shaping Non-Attainment State Implementation Plans

As states continue to revise state implementation plans (SIP) to meet the requirements of the Clean Air Act (CAA), two recent decisions out of the Ninth Circuit Court of Appeals are likely to affect how contingency measures...more

The Gaining Momentum Surrounding Carbon Capture Use and Sequestration: Overcoming Legal and Regulatory Hurdles

As the country, policymakers and industry focus on reducing greenhouse gas (GHG) emissions, carbon capture use and sequestration (CCUS) has become an important piece of the solution. CCUS is capturing carbon dioxide (CO2)...more

The CLEAN Future Act of 2021: An In-Depth Look

On March 2, 2021, the House Energy and Commerce Committee introduced H.R.1512 (117), the “Climate Leadership and Environmental Action for our Nation’s Future Act” or the “CLEAN Future Act.” The committee first unveiled the...more

Acting SEC Chair’s Directive Signals Changes Coming for Climate Risk Disclosures

The acting chair of the U.S. Securities and Exchange Commission (“SEC”) last week issued a statement (available here) directing the agency to focus on climate-related disclosures in public company filings. The statement is in...more

D.C. Circuit Vacates Portions of EPA’s 2018 Ozone Implementation Rule

On Friday Jan. 29, 2021, the United States Court of Appeals for the D.C. Circuit in Sierra Club v. EPA, Case No. 15-1465, struck down several provisions in EPA’s 2018 rule implementing the 2008 National Ambient Air Quality...more

It’s Back: the Congressional Review Act and Implications for Recent Environmental Rules

President-elect Joe Biden has already pledged to undo the repeal of nearly 100 public health and environmental laws, noting that he will consider every tool available to do so. With Democratic control of Congress and the...more

District Court Ruling on Keystone XL Pipeline Vacates Entire Nationwide Permit 12, Sows Chaos

In a decision with sweeping consequences for infrastructure projects authorized by nationwide permits, a federal district judge in Montana on Wednesday ruled that the U.S. Army Corps of Engineers (Corps) violated provisions...more

EPA Issues Guidance for Cleanup and Emergency Response Field Work During COVID-19 Pandemic

As a follow-up to our recent alert regarding the U.S. Environmental Protection Agency’s (EPA) enforcement discretion memo, last Friday EPA published further interim guidance specifically relating to field work at cleanup and...more

EPA Issues Enforcement Discretion Policy During COVID-19

The Environmental Protection Agency (EPA) has issued a memorandum describing how and when the Agency will implement temporary enforcement discretion for certain federal environmental noncompliance during the COVID-19...more

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