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The Wharf District Council “District Protection & Resiliency Plan”: There’s a Lot to Do

The Wharf District Council recently released its “District Protection and Resiliency Plan.”  My immediate reaction is just a quiet OMG regarding the size of the task.  Of course, that’s no excuse for inaction and I found the...more

What Happens When the EPA Technical Staff Disagrees with the Clean Air Science Advisory Committee?

Last week, the EPA Clean Air Science Advisory Committee provided EPA its review of EPA’s Policy Assessment for the Reconsideration of the National Ambient Air Quality Standard for ozone. As expected, CASAC has disagreed with...more

Deja Vu One More Time? What Will Happen If EPA Ignores CASAC Regarding the Ozone NAAQS?

Last week, Inside EPA (subscription required) reported that the Clean Air Science Advisory Committee has pretty much agreed that the National Ambient Air Quality Standards for ozone must be made more stringent. Apparently,...more

EPA Proposes Safe Drinking Water Act Standards for PFAS: Forever Chemicals Will Lead to Forever Superfund Sites

On March 14, 2023, EPA proposed to regulate certain PFAS under the Safe Drinking Water Act.  EPA proposed Maximum Contaminant Level Goals for PFOA and PFOS of zero.  It proposed Maximum Contaminant Levels for PFOA and PFOS of...more

It’s More Important for EPA to Ensure that States Are Good Neighbors Than That They are Perfect Neighbors

Last week, D.C. Circuit Court of Appeals rejected challenges to EPA’s “Revised Cross-State Air Pollution Update Rule”. The Court found that the Rule was “an appropriate exercise of EPA’s statutory authority”....more

News Flash! International Cooperation on the Environment Remains Possible

In these times of much woe, it’s always noteworthy when the mainstream media reports good news. Especially when it’s good news about effective international cooperation on environmental protection issues....more

Some “Big Lifts” For Boston to Achieve Its Climate Goals

Earlier this Month, The Boston Foundation released its “Inaugural Boston Climate Progress Report.” Suffice it to say, there’s a lot to do. The Report identifies four “Big Lifts” necessary to attaining our climate goals. It...more

Can Cumulative Impact Analysis Improve Cost-Benefit Analysis?

As frequent readers know, I am a big fan of cost-benefit analysis. The basic idea is that, when we make a decision to regulate at a certain level, we are by definition deciding that regulating to that level is “worth” the...more

Is Momentum Building To Change the Way We Manage Plastic?

There has been a reasonable amount of recent activity related to management (or lack thereof) of plastic waste. Two more developments this month have me wondering whether we might be near the proverbial tipping point in our...more

FWS and NOAA Decide That “Habitat” Should Not Be Defined By Regulation: I Hope This Is Good News

This week, the Fish and Wildlife Service and the National Oceanic and Atmospheric Administration issued a rule rescinding the rule issued in 2020 defining “habitat” for the purposes of determining what constitutes “critical...more

More About NEPA Reform; It’s Not Just About Renewable Energy

Last month, Oakland Mayor Libby Schaaf wrote to the Federal Highway Administration, stating that Oakland “is suffering from a crippling housing and homelessness crisis.”...more

CEQ Finalizes Phase I NEPA Regulations: Undoing Trump’s Regulations Is One Thing; Modernizing NEPA Is Another

Earlier this week, the Council on Environmental Quality promulgated its Phase I rule amending the NEPA regulations.  The final rule largely implements the proposed rule, though with some minor changes.  Since the final rule...more

PM2.5 Emissions From Wildfires -- No Longer So Exceptional!

Last week, the Clean Air Scientific Advisory Committee formally transmitted its recommendations to EPA Administrator Regan regarding the PM2.5 NAAQS. Consistent with trade press reporting over the past few months, the...more

In a Grim World, Even a Sliver of Positive Environmental News Is a Good Thing

Earlier this week, the United National Environmental Programme (doesn’t everything just look better with British spelling!) announced that 175 nations had approved a resolution titled “End plastic pollution: Towards an...more

EPA Region 1 Really Does March to the Beat of Its Own Drummer

Jerry Anderson of Drake University Law School recently did an interesting post regarding environmental enforcement. I recommend the full post, but I particularly wanted to bring my readers’ attention to a figure Jerry...more

The Internal Combustion Engine Is Bad For Your Health — What Should We Do About It?

I’ve written a lot about how the developing science around particulate exposure supports making the PM2.5 NAAQS more stringent. So it won’t come as a surprise that a new study published in the Proceedings of the National...more

Will We Ever Stop Overestimating the Cost of Complying with Environmental Regulations?

Earlier this week, Greenwire (subscription required) had an interesting story about the role that EPA’s estimate of the cost to comply with the Mercury and Air Toxics Standards rule played in the politics and judicial review...more

How To Straighten the Long and Winding Road that We Call NEPA

So CEQ has proposed to amend the NEPA regulations in order to eliminate some of the changes made by the Trump Administration in 2020. Important changes include: • explicit consideration of indirect impacts • renewed...more

There’s No Doubt What EPA Staff Thinks Should Be the Result of EPA’s Reconsideration of the PM2.5 NAAQS

Late last week, EPA released an external review draft of the “Supplement to the 2019 Integrated Science Assessment for Particulate Matter.” For those of you who don’t recall, the original Integrated Science Assessment was the...more

It’s Important to Acknowledge Good News — The End of Leaded Gasoline

As climate change rightly has dominated recent discussions of environmental policy, it’s been easy to forget how much progress has been made in the past fifty years. I was reminded of the extent of that progress by the story...more

NSR Enforcement Lives On (For Now) — A Split Decision for Ameren

The 8th Circuit Court of Appeals has largely affirmed a District Court order finding that Ameren Missouri violated the NSR provisions of the Clean Air Act in making major modifications to its Rush Island facility. The...more

The Sacketts Got Their Day in Court on the Merits; Another Lesson in Being Careful What You Wish For

Last week, in what may or may not be the last round in the ongoing efforts by Michael and Chantell Sackett to build a house on wetlands in Idaho, the 9th Circuit Court of Appeals found that: EPA reasonably determined...more

Criticizing WOTUS Is Like Shooting Fish in a Barrel

On Wednesday, EPA and the Army Corps of Engineers announced that they plan to revise the definition of “Waters of the United States”. Simultaneously, DOJ moved to remand the Navigable Waters Protection Rule, in a challenge...more

I May Agree With This EPA On Most Issues, But I Still Don’t Like Guidance

One of the results of the November election that makes me happiest is that I can now go back to being part of the loyal opposition. In other words, I know that the Administration and I share a common mission and common...more

How Are We Really Going to Get to Net Zero?

Late last month, the Washington Legislature passed the “Climate Commitment Act”, a piece of sweeping climate legislation that includes, among other provisions, an economy-wide cap-and-trade system. Washington was not far...more

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