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PFAS Designated as CERCLA Hazardous Substances

On April 19, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of the long-awaited final rule designating two per- and polyfluoroalkyl substances (PFAS) as “hazardous substances” under the...more

Air & Climate Report: April 2022

With spring finally arriving, the long-expected avalanche of EPA activity on air issues has also arrived. In this second year of the Biden administration, following the pattern of prior administrations, we are starting to see...more

Natural Gas Processors to Report to EPA’s Toxic Release Inventory Beginning 2023

In a final rule published in the Federal Register on November 24, the Environmental Protection Agency (EPA) quietly finalized a hotly contested proposed rule, adding natural gas processing facilities to the list of industry...more

EPA Announces New “Strategic Roadmap” for PFAS

Yesterday, the U.S. Environmental Protection Agency (EPA) announced a new “Strategic Roadmap (Roadmap),” describing a suite of ongoing and future agency actions to address per- and polyfluoroalkyl substances (PFAS). While...more

Penalizing Unavoidable Air Emissions: The Fight Over SSM Continues

At the end of September, the Environmental Protection Agency (EPA) issued yet another memorandum regarding emissions resulting from startup, shutdown, and malfunctions (SSM) at stationary sources of air pollutants, such as...more

Environmental Justice to Play Significant Role in Air Permitting Process Under Biden Administration

Although environmental justice (EJ) is not a new concept in the context of air permitting, the Biden administration’s increased focus on identifying and addressing disproportionate environmental impacts on low-income...more

Preparing for a More Aggressive Federal Environmental Enforcement Regime

The Biden administration has already taken several actions that signal its intention to shift to a more federally focused environmental enforcement approach. Although the Trump administration generally adopted a “hands off”...more

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