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A Change of Tune for Natural Resources Law

On June 28, in Loper Bright Enterprises v. Raimondo, the Supreme Court overruled its landmark decision in Chevron v. Natural Resources Defense Council, which gave rise to the Chevron doctrine. The Chevron case, decided in...more

Back Again: EPA Issues its Third Iteration of CO2 Reduction Rules for the Power Sector

On April 24, 2024, the U.S. Environmental Protection Agency (“EPA”) issued a final rule mandating aggressive carbon dioxide (CO2) emissions reductions from existing coal-fired power plants and new natural gas-fired turbines...more

PFAS, They Did It Again: EPA Designates Two PFAS as Hazardous Substances Under CERCLA

It has been a busy month for federal developments concerning per- and polyfluoroalkyl substances (“PFAS”). On April 19, the U.S. Environmental Protection Agency (“EPA”) made headlines again, announcing the prepublication...more

BLM Finalizes Regulations to Reduce Flaring, Natural Gas Waste on Federal and Indian Leases

On April 10, 2024, the Bureau of Land Management (BLM) issued a long-awaited final rule updating its venting and flaring requirements on federal and Indian leases, imposing new requirements to establish plans for gas takeaway...more

Impact of Colorado Carbon Capture Legislation on Oil and Natural Gas Producers

State proposal to expand carbon capture authority also proposes changes to the Oil and Gas Conservation Act As part of a bill revising aspects of the Colorado Energy and Carbon Management Commission’s (ECMC) (f/k/a Colorado...more

Colorado Bill Seeks to Expand ECMC Authority Over Carbon Management

Building on 2023 legislation granting the Colorado Energy and Carbon Management Commission (ECMC) authority over wells used to inject and permanently sequester carbon dioxide (CO2), the Colorado General Assembly is...more

Wyoming Passes Bill to Bolster Carbon Management Opportunities

With interest and activity in carbon capture, sequestration and storage and low carbon energy production ramping up, especially in Wyoming, the energy industry is celebrating the signing of HB0032. The bill, titled “Geologic...more

EPA Proposes Two PFAS-Related Rules Under RCRA. More May Be on the Way

On Feb. 8, 2024, the U.S. Environmental Protection Agency (“EPA”) released two proposed rules addressing per- and polyfluoroalkyl substances (“PFAS”) under the Resource Conservation and Recovery Act (“RCRA”). One proposed...more

Forest Service Proposes Regulatory Amendments to Permit Carbon Sequestration on NFS Lands

On Nov. 3, 2023, the U.S. Forest Service issued a proposed rule to amend its special use regulations to authorize carbon dioxide (CO2) sequestration on National Forest System (NFS) lands (both national forests and...more

New Federal Funding to Plug and Abandon Orphaned Wells, Support CO2 Sequestration

Last year, the Department of Interior (DOI) updated its estimate of the number of orphaned or abandoned wells across the United States, documenting 130,000—more than double its previous estimate. The bipartisan 2021...more

EPA Proposes Significant Revisions to GHG Reporting Requirements in Subpart W

When the Environmental Protection Agency (EPA) launched the Greenhouse Gas Reporting Program (GHGRP) in 2009, the objective was to collect and publicly report greenhouse gas emissions data across certain industries. Through...more

Chevron Deference on the Chopping Block?

Supreme Court to hear case that could change landmark precedent - Earlier this month, the U.S. Supreme Court announced that during its next term it will hear a case that could overturn Chevron, U.S.A., Inc. v. NRDC, 467...more

Colorado Makes Policy Moves With an Eye Toward Regulating Carbon Sequestration

The Colorado Oil and Gas Commission Will Become the 'Energy and Carbon Management Commission,' Among Other Changes - Interest in sequestering carbon dioxide (CO2) underground is expanding in Colorado. During the first half...more

Third Time’s the Charm?

EPA Again Proposes to Regulate Greenhouse Gas Emissions from Power Plants - Today, the Environmental Protection Agency (EPA) published new proposed rules in the Federal Register to regulate greenhouse gas (GHG) emissions...more

Colorado Contemplates Expanding the Mission of Its Oil and Gas Commission

Amid increasing attention on carbon management and energy supply diversification, three Colorado legislators introduced a bill late in the session that would transform Colorado’s Oil and Gas Conservation Commission (COGCC)...more

New Year, New NEPA Guidance

CEQ Issues an Updated Framework for Agencies to Assess Greenhouse Gas Emissions and Climate Impacts Federal agencies have new guidance to analyze and disclose greenhouse gas (GHG) emissions and climate change under the...more

A New Frontier in Class VI Carbon Storage Permitting on the Horizon

A promising long-term carbon storage solution could become more viable as the federal government and several states look to speed up the Class VI injection well permitting process. The Safe Drinking Water Act requires the...more

Shifting Winds: D.C. Circuit Questions EPA Air Quality Modeling in Good Neighbor Provision Case

Late last month, the D.C. Circuit Court of Appeals heard oral arguments in Midwest Ozone Group v. EPA, the latest challenge to the Environmental Protection Agency’s (EPA) Cross-State Air Pollution Rule (CSAPR). The Good...more

The Supreme Court Overturns the Clean Power Plan—Analysis and Key Takeaways

Yesterday, the U.S. Supreme Court issued its much-anticipated opinion in the case of West Virginia v. EPA regarding the agency’s authority to regulate carbon dioxide (CO2) from new and existing coal- and gas-fired power...more

White House Broadens Support for Hydrogen in This Week's Clean Energy Announcements

This week, the Biden administration announced several actions to expand its support for the clean energy economy. While much of the focus has been on solar energy, the White House also made important announcements for the...more

Department of Energy Announces Significant Investment in Direct Air Capture

Last week, the U.S. Department of Energy (“DOE”) released a notice of intent to fund the 2021 Infrastructure Investment and Jobs Act’s program for direct air capture (“DAC”) of carbon dioxide at four regional hubs. The...more

CEQ Restores the Status Quo with Phase 1 Changes to NEPA Regulations

On Wednesday, April 20, the Council on Environmental Quality (CEQ) published a final rule completing the first stage of rulemaking to revise certain provisions of the National Environmental Policy Act’s (NEPA) implementing...more

Biden Administration Reopens Federal Lands for Oil and Gas Leasing Under Reformed Program

The Biden administration will resume federal oil and gas leasing in June with a large reduction in acres available for drilling and a historic royalty rate increase. On April 18, 2022, the Bureau of Land Management (“BLM”)...more

EPA Looks to Expand Ozone Transport Rule West and to New Sources

The Environmental Protection Agency (EPA) recently proposed a Federal Implementation Plan (FIP) that has important implications for powerplants and other industrial nitrogen oxide (NOx) sources in the Western United States,...more

Western States Partner on Clean Hydrogen Hub

On Feb. 23, 2022, the governors of Colorado, New Mexico, Utah and Wyoming entered into a memorandum of understanding (“MOU”) to develop the Western Inter-State Clean Hydrogen Hub. Hydrogen is viewed as an essential component...more

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