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Unleashing American Energy: Trump Administration’s Latest Executive Orders

New Executive Orders and Proclamation - On April 8, 2025, President Donald J. Trump issued three significant executive orders (“EOs”) and a fourth proclamation consistent with his pledge to “Unleash American Energy.” These...more

Climate Change Litigation – State Tort Cases Move Ahead

Climate change-related litigation has been increasing in the United States for the past several years. Not only have the actual number of these types of cases increased, but the claims raised in these cases have been...more

Supreme Court Limits EPA’s Authority under the Clean Air Act

After seven years, three presidential administrations, and two appearances before the Supreme Court, the Obama Administration’s “Clean Power Plan” (“CPP”)—a Clean Air Act regulation designed to limit carbon emissions from...more

Energy Infrastructure Today: Permitting & FERC Case Law Updates

Stakeholders in the U.S. infrastructure industry should note that ongoing litigation and new court decisions issued in the first half of 2020 are reshaping the development of energy projects....more

CWA Update: Two Recent Cases Impact CWA Permitting and Enforcement

Two recent cases have the potential to dramatically alter the state of permitting and enforcement under the federal Clean Water Act (“CWA”) with far reaching implications to energy infrastructure project proponents and the...more

A Government Contractor Has a Rendezvous with the Bestfoods Decision

Twenty-two years after the Supreme Court’s ruling in Bestfoods, a government contractor—PPG Industries, Inc. (“PPG”)—comes face to face with one of the most important tenets of that court’s decision: operator liability under...more

The Supremes Weigh in on Superfund and the Clean Water Act

Notwithstanding that the Comprehensive Environmental Response, Compensation, and Liability Act (more commonly known as “Superfund”) has been around for 40 years, and the fact that numerous cases have made their way to the...more

EPA Reverses Course with the Mercury and Air Toxics Regulations for Power Plants

The saga for regulating mercury and air toxics from coal- and oil-fired power plants continues with a final rule promulgated by the U.S. Environmental Protection Agency (“EPA”) on April 16, 2020. EPA initially determined that...more

How to Manage COVID-19 Waste

The surge in COVID-19 patients has led to a sharp rise in medical waste that could carry the novel coronavirus. One common question raised by the COVID-19 outbreak is how to properly manage and dispose of...more

EPA Takes a Case-by-Case Approach in New Guidance for Cleanups and Emergency Response Actions: A First in Its History

On April 10, the U.S. Environmental Protection Agency (“EPA”) released its latest coronavirus COVID-19 Guidance addressing cleanups and emergency response actions that are being conducted under various environmental laws,...more

EPA Announces New Policy Regarding Enforcement Discretion

Due to the coronavirus COVID-19 pandemic, the U.S. Environmental Protection Agency (“EPA”) announced a Policy that will effectively relax civil enforcement in certain circumstances. The EPA recognizes that worker shortages...more

EHS Management During the Coronavirus Pandemic: Proactive Measures

The novel coronavirus (“COVID-19”) pandemic has caused significant personal and business disruptions to virtually every aspect of life. Businesses are being challenged by the financial markets, supply chain threats,...more

Coronavirus: OSHA’s and EPA’s Response

As the world’s attention turns increasingly (and almost exclusively) to the spread of COVID-19 (the coronavirus), we want to take this opportunity to highlight two important federal agency responses from the U.S. Occupational...more

Pennsylvania Plans to Join the RGGI CO2 Cap-and-Trade Program

At the outset of 2019, Pennsylvania Governor Tom Wolf set a goal for Pennsylvania to significantly reduce greenhouse gas emissions. Now, Governor Wolf plans to achieve that goal by taking the bold step to establish a carbon...more

Leveling the Playing Field against Federal Agency Regulatory Interpretation: The Supreme Court’s Kisor Decision and the U.S....

Last month, the Supreme Court in Kisor v. Wilkie, 139 S.Ct. 2400 (2019) upheld what is known in administrative law as Auer deference: the age-old principle that a court should defer to an agency when the agency is...more

Charting Climate Change Cases: A Survey of Recent Litigation

Introduction - Right now, cases involving climate change are being heavily litigated in courts across the United States. Hundreds of climate change-related cases have been filed in both federal and state courts, where...more

Pipeline Update: Here Today, Gone Tomorrow? FERC’s Natural Gas Pipeline Greenhouse Gas Analysis Policy

The Republican majority of the Federal Energy Regulatory Commission (“FERC” or “Commission”) has drawn a clear distinction with how and when the Commission will analyze upstream and downstream greenhouse gas (“GHG”) emissions...more

Pipeline Update: Pennsylvania Commonwealth Court Allows Environmental Rights Amendment Challenge to Sunoco Pipeline’s Mariner East...

The Pennsylvania Commonwealth Court recently ruled that a challenge to Sunoco Pipeline L.P.’s (“Sunoco”) Mariner East Project under Article 1, Section 27 of the Pennsylvania Constitution (the “Environmental Rights Amendment”...more

Pennsylvania Superior Court Fractures Long-Standing Rule of Capture

Citing distinctions between hydraulic fracturing and conventional gas drilling, the Pennsylvania Superior Court held on April 2, 2018, in Briggs v. Southwestern Energy Production Company that the rule of capture does not...more

FERC Advances the Ball on Electric Storage, Calls for a Huddle on Distributed Energy Resource Aggregation

In a move that has excited the renewable energy and electric storage industries, the Federal Energy Regulatory Commission (“FERC”) last month voted to remove barriers to the participation of electric storage resources in the...more

U.S. Court of Appeals for the District of Columbia Circuit Issues Decision on Definition of Solid Waste

In American Petroleum Institute (“API”) v. Environmental Protection Agency (“EPA”), the D.C. Circuit upheld, severed, and vacated portions of a 2015 EPA final rule, Definition of SolidWaste (the “Final Rule”). As explained...more

FERC Responds Quickly and Decisively to D.C. Circuit Remand in Sabal Trail Matter on Downstream GHG Analysis

The Federal Energy Regulatory Commission (“FERC”) weighed in rapidly and decisively on the Sabal Trail (a/k/a Southeast Market Pipelines or “SMP Project”) case that the D.C. Circuit remanded to it on August 22, 2017. As...more

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