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What Happens When Agency Administrators Don't Support the Agency's Statutory Mission?

I’ve always taken the position that, no matter how much I disagree with the President, the Senate should confirm his executive branch nominees (nominations to the Judicial Branch are different, since judges don’t work for the...more

A Fossil-Forward U.S. Energy Policy Begins to Take Shape under Trump

President Trump began his second term by issuing a barrage of executive orders, memoranda, and other directives, many of which targeted U.S. energy policy and the federal employees who implement it. Trump had campaigned on...more

Montana Protects a Constitutional Right to a Stable Climate: Will Any Other States Follow Suit?

Earlier this week, the Montana Supreme Court affirmed a lower court ruling in favor of plaintiffs in a climate case based on certain provisions of the Montana constitution. Specifically, the court ruled that: - The...more

We’re From the Government and We’re Here to Help You; NPDES Permit Flexibility Edition

Inside EPA (subscription required) reported this week that a group of Democratic state attorneys general have filed an amicus brief supporting EPA’s appeal of a 9th Circuit Court of Appeals decision holding that EPA had...more

The SJC Provides New Guidance to Litigants in Anti-SLAPP Cases; I’m not Optimistic

Last week, in Bristol Asphalt v. Rochester Bituminous Products, the SJC jettisoned two prior decisions and revised its directions to lower courts regarding how to handle “special motions to dismiss” under Massachusetts’...more

Does EPA Have Authority to Include Narrative Criteria in NPDES Permits? Yes, For Now.

Earlier this week, the 9th Circuit Court of Appeals affirmed EPA’s NPDES permit issued to San Francisco’s Oceanside sewer system. San Francisco had challenged the permit on the ground that EPA does not have authority to...more

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

MassDEP Proposes Cumulative Impact Analysis Regulations — It’s About to Get Interesting.

After more than a year of work, MassDEP has proposed regulations that would require applicants to perform cumulative impact analysis prior to issuance of certain air emissions permits.  The regulations were required by the...more

Implementing Maui Remains a Case-by-Case Affair, at Least for Now

Last week, EPA withdrew guidance issued in the waning days of the Trump Administration interpreting the Supreme Court decision in County of Maui v. Hawaii Wildlife Fund. As the masochists who follow the torturous case law we...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

Can “Guidance” Ever Be Binding?

Last week, the 9th Circuit Court of Appeals rejected a challenge to EPA guidance that suggested a new statistical method, the Test of Significant Toxicity, for determining the toxicity of discharges subject to NPDES permits. ...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

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

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

President Biden Pulls the Plug on Keystone XL — Let’s Make Sure It Sets the Right Precedent

Yesterday, President Biden hit the ground running on environmental policy, issuing an Executive Order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis. There’s a lot in it,...more

Who Gets To Decide What is a Major Source That Requires a Permit? That’s a Fine Question

Over the past decade, there has been an unprecedented shift in investor focus toward the analysis use of Environmental, Social and Corporate Governance (ESG) risks and impacts in investment decision-making. While the...more

Dog Bites Man, Pebble Mine Edition | Law and the Environment

As Bloomberg (subscription required) reported this week, executives of Pebble Partnership, which is developing the Pebble Mine project in Bristol Bay, Alaska, were caught on tape bragging about their political influence.  The...more

9/25/2020  /  Investigations , Mining , Permits

Governor Jim Justice and the Progress of Man

On Monday, Judge David Faber found Bluestone Coal Corporation liable for 1,904 days of violations of its discharge permit at the Red Fox Surface Mine. All of the violations related to excessive discharges of selenium. ...more

SCOTUS Gets One Right: Discharges To Groundwater Require Permits, But Only If They Are the Functional Equivalent of a Direct...

The Supreme Court ruled today that discharges to groundwater are subject to the permitting requirements of the Clean Water Act, but only where the “discharge is the functional equivalent of a direct discharge from the point...more

Injunctive Relief Is Available Outside the Fenceline

On Monday, District Judge Rodney Sippel ordered sweeping injunctive relief against Ameren Missouri, intended to remedy violations of PSD requirements he had previously identified resulting from upgrades to the Ameren Missouri...more

Deadlines For Permit Issuance Are Double-Edged Swords

On January 25, 2019, the D.C. Circuit Court of Appeals ruled that applicants for licenses under the Federal Power Act may not reach private agreements with states to circumvent the FPA requirement that states act on water...more

And Then There Were Three: Why Is Massachusetts Still Refusing to Seek NPDES Delegation?

As readers of this space know, I have been mystified by the opposition in Massachusetts to obtaining delegation of the NPDES Program. In my temperate way, I have called it an embarrassment. I have just learned that Idaho...more

Coming Soon To a Massachusetts Facility Near You: More Citizen Enforcement?

Earlier this week, the Massachusetts Executive Office of Environmental Affairs went live with two new web sites intended to increase the public availability of information concerning regulated entities in Massachusetts. The...more

EPA Delays Compliance with Massachusetts MS4 Permit

On July 13, 2017, EPA extended the compliance deadline for its General Permit for Small Municipal Separate Storm Sewer Systems for one year, until July 1, 2018. The move almost certainly prompted a collective sigh of relief...more

Promulgation of TMDLs Does Not Create a Non-Discretionary Duty to Require NPDES Permits

When EPA approved total maximum daily loads for the Charles River, but failed to require NPDES permits for persons discharging stormwater to the Charles, CLF sued. CLF alleged that EPA violated a non-discretionary duty when...more

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