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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

Maura Healey Has a Climate Plan: Is It Too Ambitious Or Not Ambitious Enough?

Take my predictions with a grain of salt, because I still remember saying that Ronald Reagan would never fool enough voters to get elected, but it seems very likely at this point that Maura Healey will be the next Governor of...more

Microplastics in the Lungs: The Next Asbestos or Are We Just Catastrophizing?

Two developments this week got me thinking about how our government deals – or fails to deal – with risk.  First, EPA proposed to ban the manufacture (including import) of chrysotile asbestos...more

The Latest IPCC Report — How Are We Doing on Mitigation?

Earlier this month, the Intergovernmental Panel on Climate Change released Climate Change 2022: Mitigation of Climate Change.  As all IPCC reports are, it’s a serious piece of work and not easily summarized at blog length...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

Boston Promulgates BERDO “Phase I” Regulations: Emissions Standards For Buildings Are Coming Soon

The Boston Air Pollution Control Commission has formally adopted its “Building Emissions Reduction and Disclosure Ordinance Phase 1 Regulations.” The Phase 1 regulations are really all about the “disclosure” side of BERDO. ...more

AIG Integrates Climate Into Its Investment and Underwriting Decisions: It’s Progress, But Is It Enough?

Last week, AIG significantly restricted its underwriting of and investment in fossil fuel projects. Specifically, it announced the following actions: With immediate effect, committed to no longer invest in or provide...more

The D.C. Circuit Again Requires FERC to Consider the Environmental Impacts of Downstream Use of Gas: How Big a Deal Is It?

Last week, the District of Columbia Court of Appeals again rejected a FERC NEPA review for failure to assess the climate impacts resulting from the downstream use of natural gas supplied by a gas pipeline upgrade project...more

The Social Cost of Carbon Lives! The Red States Have Nothing To Complain About

The Fifth Circuit has stayed an order blocking Biden administration use of the “Interim Estimates” of the social cost of greenhouse gases.  The Court did not leave much doubt that the administration will prevail on the...more

EPA Restores the California Advanced Clean Car Program; GHG Emissions From Transportation Will Continue For Some Time

EPA has now formally restored its waiver under § 209(b) of the Clean Air Act that allows California’s greenhouse gas emissions standards and Zero Emission Vehicle mandate, notwithstanding the preemption of state vehicle...more

Shareholder Activism or Divestment? The Massachusetts Pension Fund Chooses Activism

The Boston Globe reported yesterday that the Massachusetts Pension Reserves Investment Management Board approved investment guidelines that would have the Board vote against directors of companies in which the Board invests...more

The Impact of Exposure to Leaded Gasoline Was Horrific: Will We Say the Same in 2050 About the Impact of PM2.5 Exposure?

An article in the Proceedings of the National Academy of Sciences (login required) has documented the devastating impact caused by the use of leaded gasoline. The study estimates that more than half of Americans alive in...more

DOJ Gets Off Its Moral High Horse: Ameren Missouri Will Close Early

In January, I noted that Ameren Missouri had surrendered in its defense of the NSR enforcement action brought by DOJ with respect to the Rush Island generating facility.  Ameren Missouri submitted to the Court a proposal to...more

AIG Integrates Climate Into Its Investment and Underwriting Decisions: It's Progress, But Is It Enough?

Last week, AIG significantly restricted its underwriting of and investment in fossil fuel projects. Specifically, it announced the following actions: With immediate effect, committed to no longer invest in or provide...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

Shareholder Activism or Divestment? The Massachusetts Pension Fund Chooses Activism

The Boston Globe reported yesterday that the Massachusetts Pension Reserves Investment Management Board approved investment guidelines that would have the Board vote against directors of companies in which the Board invests...more

Some Say the World Will End in Climate Change, Some Say in Plastic

For those of you who don’t think that worrying about climate change is enough to keep you busy, you might want to take a look at this study commissioned by the WWF, Impacts of Plastic Pollution in the Oceans on Marine...more

State Law Climate Damage Cases (Still) Belong in State Court

In the first appellate decision to decide the issue since the Supreme Court decision in BP P.L.C. v. Mayor & City Council of Baltimore, the 10th Circuit ruled this week that climate damage claims brought by several Colorado...more

It’s Still (Again) Necessary and Appropriate to Regulate Air Toxics From Power Plants

EPA has proposed to revoke the Trump administration finding in 2020 that it is not appropriate and necessary to regulate emissions of air toxics from coal- and oil-fired electric generating units.  Instead, EPA proposes to...more

What’s Up With the Supreme Court?

As everyone knows, the Supreme Court has teed up West Virginia v. EPA, which challenges EPA’s authority to regulate greenhouse gases, and Sackett v. EPA, which challenges EPA’s authority to define what constitutes a water of...more

Have I Mentioned That It’s Not Going to Be Easy to Get to Net Zero?

Believing in the importance of aggressive action to address climate change is something of a recipe for bipolar disorder. Trump – depression. Biden first 90 days – elation. News today from ClimateWire (subscription...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

DOJ Doesn’t Know How to Declare Victory

According to Inside EPA (subscription required), the Department of Justice (and the Sierra Club) have opposed Ameren’s Missouri’s motion to allow it to close its Rush Island generating facility early, rather than install...more

BERDO Implementation Picks Up Speed — Better Get Ready

On Monday, Boston released a draft of the first phase of regulations intended to implement the amended BERDO ordinance signed by then-Mayor Janey in October. The first phase of the regulations is focused only on reporting...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

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