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On WOTUS Notice: EPA Gives Notice of Yet Another Clean Water Act Rule

The Agency Is Looking to Sackett v. EPA for a More ‘Durable’ Definition - From Obama to Trump to Biden, each of the last three administrations has directed the United States Environmental Protection Agency (“EPA”) to...more

Supreme Court Makes Waves In San Francisco Ruling

When the Supreme Court issued its decision in City & County of San Francisco v. EPA on March 4, 2025, it may have saved San Francisco $10 billion dollars in penalties sought by the United States Environmental Protection...more

Leading the Way: New EPA Rule Gives 10 Years to Replace Lead Drinking Water Service Lines

Under the U.S. Environmental Protection Agency’s (EPA) Lead and Copper Rule Improvements (LCRI) announced on Oct. 8, 2024, EPA has shifted its focus from addressing lead exceedances in drinking water to preventing lead in...more

EPA Finalizes National Recommended Aquatic Life Criteria and Benchmarks for Select PFAS

New discharge limits may be coming for certain Clean Water Act (“CWA”) National Pollutant Discharge Elimination System (“NPDES”) permits. In late September, EPA finalized national recommended water quality criteria for two of...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

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

Tenth Circuit Weighs In on Maui’s “Functional Equivalent” Test

The Tenth Circuit became the second federal appellate court—after the Ninth Circuit—to analyze how federal district courts should evaluate whether a discharge of pollutants to groundwater is the “functional equivalent” of a...more

EPA Pushes Forward with Final PFAS Reporting Regulations

On Nov. 13, 2023, the U.S. Environmental Protection Agency’s (“EPA”) final rule went into effect requiring companies to report the manufacture or import of per- and poly- fluoroalkyl substances (“PFAS”), also known as...more

Here We WOTUS Again

On Aug. 29, 2023, the Biden administration issued a prepublication version of yet another final Clean Water Act rule (“Conforming Rule”) revising the definition of “waters of the United States” (“WOTUS”) in response to the...more

EPA Delays PFAS CERCLA Designation, Other PFAS Regulatory Efforts on Schedule

The Environmental Protection Agency’s (EPA) Spring 2023 Unified Agenda, released on June 13, 2023, extends EPA’s estimated publication of a final rule designating certain per- and polyfluoroalkyl substances (PFAS)—namely...more

Change is Afoot: EPA Revisiting Section 401 Program

More changes are ahead for entities seeking federal authorization for projects that may impact waters of the United States. On June 9, 2022, the Environmental Protection Agency (“EPA”) published a proposed rule that would...more

Here Today, Gone Tomorrow? Supreme Court Uses Emergency Docket to Weigh-in on Section 401 Program

Entities seeking federal authorization for infrastructure projects that may impact waters of the United States must obtain a Section 401 certification under the Trump administration’s narrowed Section 401 certification...more

Navigable Waters Protection Rule Takes Effect in Colorado

The proper definition of “waters of the United States” is fiercely debated, and debatable. The Trump administration’s foray into the definition—the Navigable Waters Protection Rule (“NWPR”)—was issued in mid-2020 and...more

Discharge Permits Not Required to Transfer Water: Court Upholds EPA Rule

The U.S. Court of Appeals for the Second Circuit recently issued a long-awaited ruling confirming the legality of the Environmental Protection Agency’s (“EPA’s”) Water Transfers Rule in Catskill Mountains Chapter of Trout...more

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