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EPA Finalizes Revisions to Risk Management Program (RMP) Regulations, with Special Focus on Petroleum and Chemical Manufacturers

The U.S. Environmental Protection Agency (EPA) has issued a final rule (the “Rule”) that substantially expands its Risk Management Program (“RMP”) regulations aimed at preventing chemical accidents. The Rule takes effect on...more

Environmental Justice 2022 Year-End Review

Environmental Justice (“EJ”) continued to prove a major focus of the Biden administration in 2022. With wide-ranging initiatives across several federal agencies, the administration worked to strengthen enforcement, release...more

EPA’s Newest Target for Clean Air Act Enforcement: Stationary Engines

The U.S. Environmental Protection Agency (“EPA”) has announced its latest priority for Clean Air Act enforcement: stationary engines. In an enforcement alert, EPA states that it has been finding numerous violations of Clean...more

EPA Extends Comment Period for Oil and Gas Methane and VOC Emissions Rulemaking

On November 15, 2021, the Environmental Protection Agency (“EPA”) published a proposed rule that included three separate actions under the Clean Air Act that target new and existing air emission sources at oil and natural gas...more

EPA Proposes Far-Reaching Methane Rules for the Oil and Gas Sector

The first action proposes first-time emission guidelines to reduce methane emissions from almost 1 million existing oil and gas wells, almost 2,000 existing interstate natural gas compressor stations, and over 500 existing...more

“Immediately Effective” Midnight Rules — Beyond The Hour For Change Or Vulnerable To Court Challenges?

Ordinarily, the law governing how agencies create regulations — the Administrative Procedure Act — requires a thirty-day window between when a rule is published in the Federal Register and becomes “final” and when the rule is...more

Navigating The Transition: Key Environmental Enforcement Issues To Watch In The Biden Administration

While the texts of environmental laws do not change without an act of Congress, executive branch agencies that enforce those laws have a great deal of discretion in what kinds of violations to prioritize for investigation and...more

Clean Air Act General Duty Provision Is Not An Applicable Requirement For Title V Permit Purposes

EPA’s Administrator very recently issued this response to a petition to object to a Title V permit (issued to a Georgia wood pellet maker), which very helpfully concludes that the Clean Air Act Section 112(r)(1) general duty...more

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