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Will More Money Managers Start Voting Shares Based on Climate Issues? Fidelity International Gets in the Game

In the wake of Engine No.1’s successful effort to elect more climate-friendly directors at Exxon and the increasingly aggressive action by BlackRock to take climate into account in its investment management decisions, the...more

Maui Needs a NPDES Permit; What’s Next for WOTUS?

Last week, District Judge Susan Mollway ruled that the County of Maui must obtain a NPDES permit for discharges to groundwater by the Lahaina Wastewater Reclamation Facility. It is the first trial court decision applying the...more

Will Increased Enforcement Speed Cleanup of Superfund Sites in EJ Communities?

Earlier this month, EPA circulated a memorandum on “Strengthening Environmental Justice Through Cleanup Enforcement Actions.”  It could significantly increase the volume of CERCLA enforcement actions.  More importantly, if...more

At What Level of Government Are We Going to Regulate Climate Change? (Hint — It Is a Global Problem.)

Last week, Judge Yvonne Gonzalez Rogers ruled that the Berkeley ordinance essentially banning use of natural gas in new construction was not preempted by the Energy Policy and Conservation Act. I’m not here to opine on the...more

EPA Withdrawal of Its Proposed Veto of a 404 Permit Is Reviewable — This Should Not Be Earth-shattering News

Last week, the 9th Circuit Court of Appeals ruled that EPA’s decision to withdraw its proposed veto of the Army Corps’ Section 404 permit for the Pebble Mine project in Bristol Bay, Alaska, was subject to judicial review. ...more

Massachusetts Claims Against ExxonMobil Survive — Wave of the Future or Litigation Sideshow?

This week, Judge Karen Green denied Exxon Mobil’s motion to dismiss claims brought by Massachusetts under its Consumer Protection Act. The complaint alleges that Exxon Mobil both mislead Massachusetts investors in its...more

EPA Is Reconsidering the PM2.5 NAAQS. The Sooner, the Better.

EPA announced yesterday that it will “reconsider” the Trump EPA’s decision not to change the PM2.5 National Ambient Air Quality Standard. I’ve blogged numerous times about the growing body of evidence that exposure to...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

The Test For Injunctive Relief Was Not Developed By a Risk Assessor

Earlier this Month, Judge James Boasberg, who had previously ruled that the easement allowing construction of the Dakota Access Pipeline must be vacated due to a failure to comply with NEPA, nonetheless declined to issue an...more

I Love It When SCOTUS Reminds Me How Clear and Unambiguous CERCLA Is

Yesterday, the Supreme Court ruled that only settlements that explicitly resolve liability under CERCLA trigger the contribution provisions of section 113 of CERCLA. I have previously commented on the Court’s tendency to...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

Incidental Take Permits Under the Migratory Bird Treat Act — Why Is This So Difficult?

Last week, the Fish and Wildlife Service issued a proposed rule that would revoke the rule promulgated by the Trump Administration in January 2021 and return to the prior status quo, in which the incidental take of birds...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

PM2.5 and Environmental Justice - and Electric Vehicles– and Tires

I’ve frequently discussed in recent years the mounting evidence for the need to lower the National Ambient Air Quality Standard for PM2.5. There is also substantial evidence that PM exposure is an environmental justice issue....more

The Other Shoe Drops - EPA Formally Announces Its Reconsideration of the Withdrawal of the California Preemption Waiver

I noted in yesterday’s post about the NHTSA proposal to withdraw the SAFE I Rule that EPA was expected to follow the NHTSA action by restoring the Clean Air Act Section 209 waiver for California’s Advanced Clean Car program....more

The SAFE Rule Is On the Way Out - I Don’t Feel Any Less Safe

Last week, the National Highway Traffic Safety Administration proposed to withdraw Part I of the Trump Administration’s SAFE Rule, in which EPA had concluded that California’s regulation of motor vehicle GHG emissions was...more

50% By 2030 — The Administration Is Figuring Out How to Actually Get There

The President today formally announced that the United States was pledging to reduce its emissions by 50% from 2005 levels by 2030. The announcement isn’t a surprise, but that doesn’t lessen its importance. So large a...more

The Biden Administration’s Undoing Project Continues — A Flawed Interior Interpretation is Jettisoned

On Friday, the Principal Deputy Solicitor at the Department of Interior issued a memorandum on how DOI should balance the criteria in the Outer Continental Shelf Lands Act in issuing leases for offshore wind. The new...more

Carbon Pricing — Is It the Zombie Climate Policy?

At a press briefing in India yesterday, John Kerry, President Biden’s Special Presidential Envoy for Climate was asked by an Indian journalist about carbon pricing. Here’s part of his response: President Biden believes...more

4/9/2021  /  Carbon Pricing , Climate Change

Is a New Electricity Grid in Our Future? President Biden Thinks So.

The White House this morning released a fact sheet on “The American Jobs Plan,” also known as President Biden’s infrastructure plan. There’s a lot in here (as there should be for a couple of trillion dollars!), so today I’ll...more

States Really, Really, Must Act on Water Quality Certification Applications Within One Year

The saga of judicial efforts to enforce the one-year limit on state review of applications for water quality certifications under Section 401 of the Clean Water Act shows no sign of reaching a conclusion. First, in Hoopa...more

Massachusetts Climate Legislation Becomes Law - The Future of Everything

It’s not always the case, but my speculation about the Massachusetts climate bill was correct. On Friday, Governor Baker signed it into law. If I haven’t succeeded in making this clear previously, I want to emphasize that...more

The Massachusetts Climate Bill is Very Much “Not Dead”

In January, when Governor Baker vetoed the Legislature’s effort to go big on climate, my colleague Zach Gerson made clear that the bill was not even “mostly dead.” I am pleased to say that Zach’s diagnosis was correct. The...more

FERC Considers GHG Emissions in a Gas Pipeline Review — Everyone Is Unhappy

According to E&E News (subscription required), FERC yesterday, for the first time, assessed the impacts of a gas pipeline’s downstream GHG emissions.  (As of this writing, the decision is not yet available on FERC’s web...more

3/19/2021  /  FERC , Natural Gas , Oil & Gas , Pipelines

The Transportation Climate Initiative Marches Forward; It’s Not Going to Be Easy. - Law and the Environment

On March 1, the Transportation Climate Initiative jurisdictions released a draft “model rule” that would provide a template for individual state rules governing the operation of the TCI Program.  Although only three states...more

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