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Proposed WOTUS Rule Could Reduce CWA Permitting Burdens for Developers

On November 20, 2025, the Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (Corps, together the “Agencies”) published a Notice of Proposed Rulemaking (Proposed Rule) in the Federal Register to revise...more

Texas’ CCS Landscape Shifts with Class VI Primacy and Clearer Pore-Space Ownership Rules

On November 12, 2025, the U.S. Environmental Protection Agency (EPA) granted the Texas Railroad Commission (RRC) primacy over the Class VI Underground Injection Control (UIC) program, authorizing Texas to assume primary...more

No Bailout for Bureaucratic Inertia: NYDEC Ordered to Implement Albany’s Climate Commitments

In a ruling with sweeping implications for New York’s climate policy, an Albany trial court ordered the New York Department of Environmental Conservation (NYDEC or Department) to issue long-overdue regulations under the...more

EPA’s New Residential Lead Directive: Key Implications for Developers and Investors

On October 16, 2025, the U.S. Environmental Protection Agency’s (EPA) Office of Land and Emergency Management (OLEM) issued the Residential Lead Directive for CERCLA Sites and RCRA Hazardous Waste Cleanup Program Facilities...more

When Does Construction Really Begin? EPA Plans to Redefine a Key Air Permitting Threshold

The U.S. Environmental Protection Agency (EPA) has announced plans to propose, by 2026, a rule revising the definition of “begin actual construction” under the Clean Air Act’s (CAA) New Source Review (NSR) regulations. ...more

EPA Stands by PFAS Hazardous Substance Designation: Implications for Property Owners and Developers

The U.S. Environmental Protection Agency (EPA) has reaffirmed its 2024 decision to designate two PFAS chemicals—perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS)—as hazardous substances under the...more

“Death Star Bill” Survives Legal Challenge, Leaving Enforcement to Private Parties

On July 18, 2025, the Texas Third Court of Appeals in Austin dismissed a constitutional challenge to the Texas Regulatory Consistency Act (the “Act”) on standing grounds, declining to address whether the Act’s sweeping...more

Supreme Court Reins in NEPA Reviews - Clearing the Path for Developers

On May 29, 2025, the Supreme Court handed down its decision in Seven County Infrastructure Coalition v. Eagle County, No. 23-975, 605 U.S. ___ (2025), sharply limiting the scope of environmental review obligations under the...more

Trump Administration Redefines “Harm” Under The Endangered Species Act (ESA)

On April 17, 2025, the U.S. Fish and Wildlife Service and the National Marine Fisheries Service (together, the “Services”) proposed to rescind their longstanding regulatory definition of “harm”, which has for decades served...more

Regulatory Reset: Texas Establishes a DOGE-Inspired Office to Cut Red Tape

As Texas strengthens its position as a national leader in economic and business growth, Senate Bill 14 (SB 14)—signed into law on April 23, 2025, and effective September 1—marks a significant shift in the state’s regulatory...more

San Francisco v. EPA: Supreme Court Strikes Down EPA’s “End-Result” Permit Requirements

On March 4, 2025, the U.S. Supreme Court issued a 5-4 decision in City and County of San Francisco v. Environmental Protection Agency, narrowing the Environmental Protection Agency’s (EPA) authority under the Clean Water Act...more

Texas Railroad Commission’s New Environmental Rules: A Step Toward Sustainability or Business as Usual?

In 1984, while Ronald Reagan was securing a landslide reelection and Apple introduced the Macintosh, the Railroad Commission of Texas (RRC) last updated the state’s primary oil and gas waste regulations. Now, four decades...more

EPA’s PFAS Regulations: What Real Estate Professionals Need to Know

In 2024, the U.S. Environmental Protection Agency (“EPA”) took significant steps to regulate per- and polyfluoroalkyl substances (PFAS), commonly known as “forever chemicals.”...more

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