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Arizona Court Vacates Navigable Waters Protection Rule: What it Means for Your Project

In a recent decision, a federal judge in Arizona vacated the Trump Administration’s Navigable Waters Protection Rule (NWPR) and remanded the rulemaking back to U.S. Environmental Protection Agency and the U.S. Army Corps of...more

D.C. Circuit Rejects FERC’s Analysis of Greenhouse Gas Emissions and Environmental Justice Issues for Texas LNG Facilities

On August 3, 2021, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) rejected the Federal Energy Regulatory Commission’s (FERC) environmental analysis of a group of Liquified Natural Gas (LNG)...more

Biden Administration Proposes a Reset on Defining “Waters of the U.S.”

Over the past week, the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers announced plans to undo the Trump administration’s Navigable Waters Protection Rule, and take the Biden administration’s next...more

Here We Go Again: Services to Re-Revise Endangered Species Act Regulations

In an anticipated move, the U.S. Fish & Wildlife Service and National Marine Fisheries Service (the “Services”) have announced plans to again overhaul Endangered Species Act (ESA) regulations. In this latest example of “to...more

Department of the Interior Seeks to Withdraw Migratory Bird Treaty Act Liability Rule

In a proposed rule published May 7, 2021, the Biden Administration seeks to withdraw the Trump Administration’s Migratory Bird Treaty Act (MBTA) liability rule. The MBTA liability rule was published as a final rule on January...more

FERC Adopts Final Rule Formalizing One-Year Deadline for States To Issue Clean Water Act Certifications; Second Circuit Affirms...

On March 18, 2021, the Federal Energy Regulatory Commission (FERC) adopted a Final Rule requiring state agencies to issue Clean Water Act (CWA) Section 401 water quality certificates within one year of receiving a request or...more

Migratory Bird Treaty Act Liability Rule Looks to Be Short-Lived

The Biden Administration is moving quickly to undo the Trump Administration’s Migratory Bird Treaty Act (MBTA) liability rule. Published as a final rule on January 7, 2021, this rule for the first time supplied a uniform...more

Migratory Bird Treaty Act Liability Rule Finally Is Here, But For How Long?

In a long-unfolding saga, on January 7, 2021, the U.S. Fish and Wildlife Service (FWS) published its final rule that will at long last establish a clear regulatory definition of the scope of liability under the Migratory Bird...more

FERC Proposes One-Year Deadline for States to Issue Clean Water Act Certifications

Acting in response to a Trump Administration Executive Order instructing federal agencies to reduce regulatory uncertainties and expedite construction of energy infrastructure, the Federal Energy Regulatory Commission (FERC)...more

CEQ Issues NEPA Emergency Guidance

On September 14, 2020, the Council on Environmental Quality (CEQ) issued nonbinding guidance to agencies to help them comply with the National Environmental Policy Act (NEPA) during emergencies. The guidance comes less than...more

Let’s Talk “Habitat”: Competing ESA Definitions Proposed to Provide Regulatory Clarity

Under the Endangered Species Act (ESA), there are a number of key terms that shape the scope of species protection. These key terms, usually defined in the Act itself or through agency regulation, include terms such as...more

White House Completes Generational Update of NEPA Regulations

On Wednesday, July 15, 2020, the Council on Environmental Quality (CEQ) published a Final Rule updating its regulations implementing the National Environmental Policy Act (NEPA) across the federal government. 85 Fed. Reg....more

FERC Adopts New Rules for Pipeline Certificate Orders to Address Concerns of D.C. Circuit

On June 9, 2020, the Federal Energy Regulatory Commission (FERC) issued new rules designed to address concerns expressed by the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit) about abuse of landowner...more

President Trump Orders Expanded Use of Emergency Powers to Streamline Infrastructure

On Thursday, June 4, 2020, President Trump signed an Executive Order (EO) on “Accelerating the Nation’s Economic Recovery from the COVID-19 Emergency by Expediting Infrastructure Investments and Other Activities.” Relying on...more

Federal Court Nullifies Clean Water Act General Permit for Pipelines and Other Linear Projects

In an order with serious and immediate national implications for the construction of pipelines, electrical lines, fiber optic cable, and other utility projects, a Montana federal court has vacated Clean Water Act (CWA)...more

Government Proposes to Codify Limits on Migratory Bird Treaty Act Liability

The U.S. Fish and Wildlife Service (the “Service”) on February 3, 2020 issued a proposed rule that for the first time would supply a uniform regulatory definition of the scope of liability under the Migratory Bird Treaty Act...more

New WOTUS Rule Clarifies Clean Water Act Jurisdiction, Awaits Litigation

On January 23, 2020, the U.S. Environmental Protection and U.S. Army Corps of Engineers finalized a long-awaited new rule redefining the term “Waters of the United States” (WOTUS) under the Clean Water Act (CWA). The Agencies...more

D.C. Circuit En Banc Review of FERC Tolling Orders Could Have Profound Implications for Infrastructure Projects Requiring FERC...

On March 20, 2020, the U.S. Court of Appeals for the District of Columbia Circuit (DC Circuit), sitting en banc, will hear arguments challenging the Federal Energy Regulatory Commission’s (FERC) use of “tolling orders.”...more

Déjà Vu: EPA, Army Corps Take First Step to Redefine “Waters of the U.S.”

Last week EPA and the U.S. Army Corps of Engineers announced that they again will be taking the first step in the long-awaited rulemaking process to redefine the scope of “waters of the United States” (WOTUS) under the...more

New Regulations Reform Implementation of Endangered Species Act

Long-sought reforms to Endangered Species Act (ESA) implementation have arrived. On August 27, 2019, the U.S. Fish and Wildlife Service (FWS) and U.S. National Marine Fisheries Service (NMFS) finalized regulations (the 2019...more

New EPA Section 401 Guidance Clarifies Timelines for and Scope of Certification Reviews

On June 7, 2019, the U.S. Environmental Protection Agency (EPA) issued nonbinding guidance clarifying and providing recommendations regarding the implementation of Section 401 of the Clean Water Act, 33 U.S.C. § 1341. Most...more

Executive Orders Aim to Streamline Energy Infrastructure Projects 

On April 10, 2019, President Trump signed two executive orders intended to address a range of legal and procedural hurdles commonly facing infrastructure projects, particularly in the energy sector. Most notably, the...more

FWS Takes a Mulligan on Greater Sage-Grouse Listing

Effectively restarting a contentious listing process, on April 12, 2019, the United States Fish and Wildlife Service reopened public comment on 2013 proposed rules listing the Bi-State distinct population segment of greater...more

EPA and Army Corps Again Propose to Redefine Waters Regulated Under the Clean Water Act

On December 11, 2018, the U.S. Environmental Protection Agency and Army Corps of Engineers (the “agencies”) announced once again that they are proposing a new rule to redefine the scope of waters and wetlands subject to...more

Justices Request the Government’s Views on CWA Discharge Cases

On December 3, 2018, the U.S. Supreme Court requested the federal government’s views on two petitions for certiorari asking the Court to decide whether the Clean Water Act (CWA) regulates releases of pollutants that reach...more

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