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The Other Shoe Drops on Upwind Ozone States

On Tuesday, the District of Columbia Court of Appeals vacated EPA’s “Close-Out Rule,” which basically concluded that upwind states contributing to exceedances of the National Ambient Air Quality Standard for ozone in downwind...more

TMDL — It Means Total Maximum Daily Load. Literally.

Earlier this week, Judge Christopher Cooper of the District Court for the District of the Columbia, struck down EPA’s approval of Total Maximum Daily Loads established by the District of Columbia for the Anacostia and Potomac...more

Climate Change Litigation Strategy: Swing For the Fences or Hit Singles?

Those seeking to address climate change through litigation have taken two different paths. Some cases, probably best represented by Juliana v. United States, have plaintiffs who are swinging for the fences. These are...more

Asbestos. Lead Paint. MTBE. PFAS?

Late last month, New Hampshire filed two law suits seeking to recover a variety of costs and damages it alleges have resulted from contamination caused by releases of PFAS. It’s a wide ranging suit; New Hampshire asserted...more

Eliminating a Moratorium Affecting 1.86 Billion Tons of Coal Is Final Agency Action

In 2016, DOI Secretarial Order 3338 imposed a moratorium on new coal leases on federal land until BLM prepared a programmatic environmental impact statement intended to address, among other issues, the impact of coal leasing...more

Stop the Presses. Superfund is Stupid.

I know that pointing out CERCLA’s stupidity has something of a dog bites man quality, but sometimes Superfund’s stupidity bears repeating. Today’s exhibit? New York v. Next Millenium Realty, in which Judge Feuerstein held –...more

Prognosticating the Ozone Standard Litigation: EPA to Win, Environmental Petitioners to Place, Murray Energy to Show

Last week, the “Public Health and Environmental Petitioners” challenging EPA’s decision not to reduce the ozone standard below 0.070 ppm filed their “Non-Binding Statement of Issues.” My crystal ball still tells me that the...more

The Mercury Rule Lives To Fight Another Day: Vacatur Is Very Much Out of Fashion

On December 15, 2015, the D.C. Circuit Court of Appeals refused to vacate EPA’s Mercury and Air Toxics Standards. The decision was not a surprise. As I noted earlier this fall, there is a definitely trend towards refusing...more

Does Colorado Support the Clean Power Plan? Yes. And No.

I have never understood why 43 states – including the great Commonwealth of Massachusetts – have independent elected attorneys general. I’m sure my new colleague, former Massachusetts Attorney General Martha Coakley, would...more

Washington Has A Public Trust Obligation to Address Climate Change — So What?

Last week, a trial judge in Washington State, in Foster v. Washington Department of Ecology, ruled that the Public Trust Doctrine requires the State of Washington to address climate change more aggressively. Greenwire’s...more

What Do Opponents of the Clean Power Plan and the Oklahoma Sooners Have In Common?

So the Clean Power Plan has been published in the Federal Register. For those who cannot get enough, you can find all of the important materials, including EPA’s Technical Support Documents, on EPA’s web site for the CPP....more

CERCLA Remains Ridiculous: A Remedy In Operation For 18 Years Is “Short Term”

Far too frequently, we are reminded just how hard judges must work to save CERCLA from itself. The decision last week in California River Watch v. Fluor Corporation is the most recent compelling example....more

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