President Trump has issued a flurry of new Executive Orders and Presidential Memoranda aimed at advancing the Administration’s deregulatory agenda, particularly in the energy and environmental sectors. This advisory provides...more
On the heels of its March 12 major announcement about 31 deregulatory actions, EPA also issued an important Memorandum honing the National Enforcement and Compliance Initiatives (NECI’s) adopted under the Biden administration...more
We expect newly-confirmed U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin to quickly follow through on President Trump’s promises to draw down federal enforcement efforts. In a stark directive, Trump has...more
Environmental non-governmental organizations (eNGOs) looking to develop citizen suits typically first mine publicly available compliance information companies must submit to state and federal environmental agencies. eNGOs...more
We expect newly-confirmed U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin to quickly follow through on President Trump’s promises to draw down federal enforcement efforts, particularly in the arena of air...more
The U.S. Environmental Protection Agency’s (EPA) latest attempt to replace rulemaking with enforcement is in full force, notwithstanding a spate of historic Supreme Court decisions reflecting keen frustration with federal...more
Key Takeaways -
What Happened? On May 3, 2024, the U.S. Environmental Protection Agency (EPA) published its proposal to revise the Clean Air Act’s (CAA) New Source Review (NSR) preconstruction permitting program...more
The U.S. Environmental Protection Agency’s (EPA) Office of Civil Enforcement recently published an Enforcement Alert with the purported objective of “reminding” companies of their compliance obligations under the Benzene...more
On January 9, 2024, the U.S. Environmental Protection Agency (EPA) proposed amendments to its Clean Air Act (CAA) Title V operating permit rules to clarify the scope of an “applicable requirement” that can be implemented...more
Companies seeking air quality permits or permit amendments for construction of new projects under the Texas Clean Air Act’s New Source Review (NSR) program should note recent court decisions at federal, state, and...more
Last week, the U.S. Environmental Protection Agency (EPA) issued a 444-page pre-publication summary of new proposed rules intended to reduce hazardous air emissions from chemical manufacturers in the Synthetic Organic...more
The Protecting Communities from Plastics Act (S. 5163/H.R. 9388), introduced late last week by Senator Cory Booker (D-NJ), Representative Jared Huffman (D-CA-02), Senator Jeff Merkley (D-OR), and Representative Alan Lowenthal...more
On November 2, 2021, President Biden released the U.S. Methane Emissions Reduction Action Plan (the “Plan”). The Plan, calling for substantial reductions in U.S. methane emissions, was announced in tandem with an...more
Key Takeaways -
• What Happened: EPA urges self-audits for facilities subject to RCRA Parts 264/265 Subparts AA, BB and CC air emission standards to avoid potential for substantial penalties and injunctive relief
...more
On August 12, the United States Environmental Protection Agency (EPA) published the final “residual risk and technology” (RTR) rule for the Miscellaneous Organic Chemical Manufacturing (MON) source category (Final Rule or MON...more
Led by the Center for Biological Diversity, a group of 364 environmental and other non-governmental organizations have filed a petition with the U.S. Environmental Protection Agency (EPA) to revise standards applicable to...more
The definition of a “source” is the foundation of air permitting. Yet for many years, one of the most vexing questions has been how to determine which air emission sources located near each other and under common ownership or...more
Nearly three years after adopting extensive amendments to its rules on accidental release prevention under the Clean Air Act, the Environmental Protection Agency (EPA) adopted a final rule rescinding nearly all of the...more
The U.S. Environmental Protection Agency (EPA) has released a long awaited proposal to update the Accidental Release Prevention rules at 40 C.F.R. Part 68, which implement the Clean Air Act Section 112(r)(7) risk management...more
3/4/2016
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