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Supreme Court Re-Instates the Clean Water Act Section 401 Certification Rule

Today, in a 5-4 decision, the Supreme Court re-instated the U.S. Environmental Protection Agency’s (EPA’s) 2020 Clean Water Act (CWA) section 401 rule (Certification Rule). The Court stayed a decision by the U.S. District...more

FWS Proposes to Uplist Northern Long-Eared Bat

The listing status of the northern long-eared bat (NLEB) under the Endangered Species Act (ESA) has been the subject of litigation since the U.S. Fish and Wildlife Service (Service) originally listed it as threatened in 2015....more

New Guidance on the Endangered Species Act for Existing Structures

Section 7 of the Endangered Species Act (ESA) requires the Army Corps of Engineers (Corps) to consult with the National Oceanic and Atmospheric Administration Fisheries (NOAA) (together “Agencies) before undertaking work or...more

Clean Water Act Section 401 Certification Rule Litigation Continues

As the U.S. Environmental Protection Agency (EPA) prepares its Clean Water Act (CWA) Section 401 rule proposal, litigation regarding the 2020 Trump-era rule (Certification Rule) continues. Currently, the issue of whether to...more

Biden Administration Presses Forward With Revised WOTUS Rule

The Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (the “Corps”) (together the “Agencies”) have continued working on a proposed rule to revise the definition of “waters of the United States”...more

Court Decision to Vacate, Remand State Water Quality 401 Certification Rule

On October 21, the U.S. District Court for the Northern District of California vacated and remanded the U.S. Environmental Protection Agency’s (EPA) 2020 Clean Water Act Section 401 final rule (Certification Rule)....more

Biden Administration Rescinds Two Trump-Era Endangered Species Act Rules

On October 26, the Fish and Wildlife Service (FWS) and National Marine Fisheries Service (the Services) proposed to rescind two Trump-era final rules: the Habitat Definition Rule and the Designating Critical Habitat Rule....more

Infrastructure Bill Provides Opportunities for Hydroelectric Industry

On November 5th, the U.S. House of Representatives passed the more than $1.2 trillion Infrastructure Investment and Jobs Act, also known as the bipartisan infrastructure framework (BIF). The Senate had already approved the...more

District Court Vacates Navigable Waters Protection Rule

A recent decision by the U.S. District Court for the District of Arizona vacated and remanded the 2020 Navigable Waters Protection Rule (NWPR) issued by the Environmental Protection Agency (EPA) and U.S. Army Corps of...more

Biden Nominates Willie Phillips as New FERC Commissioner

On September 9, 2021, President Biden announced his intention to nominate the current Chairman of the D.C. Public Service Commission (DCPSC), Willie L. Phillips, Jr., as a Commissioner of the Federal Energy Regulatory...more

Changes to Migratory Bird Treaty Act Program Announced

On October 4, the U.S. Fish and Wildlife Service (FWS) published a revision of its interpretation of the Migratory Bird Treaty Act (MBTA). With the final rule, FWS has effectively reinstated its position that “incidental...more

Notice of Proposed Rulemaking for NEPA Revisions Announced

On October 7, the Council on Environmental Quality (CEQ) issued a Notice of Proposed Rulemaking (NOPR) to revise its regulations implementing the National Environmental Policy Act (NEPA), which requires federal agencies to...more

Department of Energy Announces Funding Opportunity for Wave Energy Converter Technology

On July 6, the U.S. Department of Energy (DOE) announced a funding opportunity for the research and development of wave energy converter (WEC) technologies for advancement toward wave energy commercial viability. As much as...more

Hydroelectric Impact of PennEast Supreme Court Gas Pipeline Condemnation Ruling

Section 7(h) of the Natural Gas Act (NGA) and Section 21 Federal Power Act (FPA) respectively vest Federal Energy Regulatory Commission (FERC or Commission) natural gas pipeline certificate holders or hydroelectric licensees...more

The Fourth Circuit Weighs in on the Interpretation of CWA Section 401

There has been a longstanding debate about how to apply the one-year time limit on Clean Water Act Section 401 certification decisions. The D.C. Circuit court in Hoopa Valley Tribe v. FERC, 913 F.3d 1099 (D.C. Cir. 2019)...more

District Court Lacked Jurisdiction Over Clean Water Act Section 404 Permit Challenge Involving FERC License Amendment

On March 31, U.S. District Judge Christine Arguello found that the Federal Power Act (FPA) is the exclusive authority with regards to controversies related to Federal Energy Regulatory Commission (FERC) -issued hydroelectric...more

6/4/2021  /  Clean Water Act , FERC , Permits , Section 404

Clean Energy Groups Ask FERC for Transparency Into “Anti-Climate” Groups

On March 17, 2021, a coalition of environmental organizations and clean energy groups led by the Center for Biological Diversity (CBD) petitioned the Federal Energy Regulatory Commission (FERC) for a rulemaking that would...more

EPA Announces Reconsideration and Potential Revision of the Clean Water Act Section 401 Final Rule

On May 27, the Environmental Protection Agency (EPA) announced its intent to reconsider the Clean Water Act (CWA) Section 401 final rule issued by the Trump administration in June 2020 (Final Rule)....more

Judge Does Not Require Dam to Alter Water Flows for ESA Species Protection

On April 15, Judge André Birotte Jr. for the U.S. District Court for the Central District of California determined that the U.S. Bureau of Reclamation’s (Bureau) operation of the Twitchell Dam with certain water flows did not...more

Second Circuit Enforces the Clean Water Act Section 401 One-Year Time Limit

On March 23, the Second Circuit issued its opinion in N.Y. Dep’t of Enviro. Conservation v. FERC, Case No. 19-1610 (i.e., the “Empire Pipeline” case). The case concerns the Federal Energy Regulatory Commission’s (FERC or...more

Biden Administration Announces Tribal Consultation Policy

The Biden administration has highlighted Tribal sovereignty and the federal trust responsibility to Tribal Nations as the cornerstones of its federal Indian policy. The involvement of Native American tribes is also a...more

Hydropower Report: January 2021

Happy new year! We begin 2021 with a transition of leadership in the Presidency and the U.S. Senate, and with the recent news that President Biden has named Richard Glick as the new FERC Chair. All of these changes in...more

FERC’s Clean Water Action Section 401 Waiver Analysis Continues to Evolve

In 2019, the D.C. Circuit in Hoopa Valley Tribe v. FERC held that the plain language of Clean Water Act (CWA) Section 401 establishes a bright-line maximum period of one year for States to act on a request for water quality...more

Personal Protective Equipment Disposal Management in the Workplace

In light of the potential for distribution of the vaccine, employers are revisiting their plans for return to work and the many challenges that office re-openings might bring, including the requirement that employees wear...more

EPA Seeks to Expedite COVID-19 Disinfectant Long-Lasting Efficacy Claims Approvals

On October 14, the Environmental Protection Agency (EPA) issued new interim guidance to expedite approvals that would allow companies to make claims regarding the residual effectiveness of long-lasting surface disinfectants...more

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