News & Analysis as of

Clean Air Act Regulatory Requirements

Mitchell, Williams, Selig, Gates & Woodyard,...

PM 2.5/Clean Air Act: Environmental Organizations Joint Letter to U.S. EPA Opposing Revisiting NAAQS

One hundred environmental organizations transmitted an April 21st letter to the United States Environmental Protection Agency (“EPA”) Administrator asking that the federal agency: …maintain and promptly implement a vital,...more

BCLP

PFAS Air Emissions Restrictions

BCLP on

When evaluating legal risk relating to per- and polyfluoroalkyl substances (“PFAS”), most businesses typically consider wastewater, groundwater, or soil impacts, not air emissions. However, state and federal regulatory...more

Mitchell, Williams, Selig, Gates & Woodyard,...

FY 2026 Federal Grant Funding for State and Local Clean Air Agencies: National Association of Clean Air Agencies Recommendations

The National Association of Clean Air Agencies (“NACAA”) issued a document titled: Recommendations for FY 2026 Federal Grant Funding for State and Local Clean Air Agencies (“Recommendations”)....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Synthetic Organic Chemical Manufacturing Industry/Polymers and Resins Industry NESHAP: American Chemistry Council/American Fuel &...

The American Chemistry Council (“ACC”) and American Fuel & Petrochemical Manufacturers (“AFPM”) sent a March 31st letter to the United States Environmental Agency (“EPA”) requesting: …a two-year exemption from the...more

Snell & Wilmer

EPA Steps Back, Arizona Moves Forward

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In a significant development for Arizona’s business community and environmental policymakers, the U.S. Environmental Protection Agency (EPA) has paused its planned reclassification of Maricopa County from “Moderate” to...more

Williams Mullen

Exceptional Events Part of North Carolina Particulate Air Quality Attainment Designation

Williams Mullen on

Effective May 2024, EPA tightened the annual health-based National Ambient Air Quality  Standard (NAAQS) for fine particulate matter (PM2.5) from 12.0 µg/m3 to 9.0 µg/m3. This change was made after a review of the available...more

Williams Mullen

Environmental Notes - April 2025

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Under the Clean Air Act, sources frequently must undergo “New Source Review” (NSR) permitting, which is a pre-construction permitting program. NSR establishes requirements for new or modified sources prior to initiating...more

Williams Mullen

Frequently Asked Air Questions (FAAQs): Synthetic Minor Permits, One-Time Doubling & Sham Permits

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Under the Clean Air Act, sources frequently must undergo “New Source Review” (NSR) permitting, which is a pre-construction permitting program. NSR establishes requirements for new or modified sources prior to initiating...more

Holland & Knight LLP

Clean Air Act Rulemakings Don't Follow the Normal Rules – Just Ask the Supreme Court

Holland & Knight LLP on

Every law student learns that the Administrative Procedure Act (APA) outlines the default rules for how federal agencies propose and finalize regulations and how courts review them. But for many significant actions under the...more

Goldberg Segalla

EPA Introduces New Email Account for Regulated Community to Request Presidential Exemption

Goldberg Segalla on

The Environmental Protection Agency announced March 12 it set up an e-mail account allowing the regulated community to request a presidential exemption under Section 112(i)(4) of the Clean Air Act (“CAA”)....more

McGlinchey Stafford

Trump Announces Presidential Exemptions Under Clean Air Act

McGlinchey Stafford on

In an unprecedented move, the Trump administration established an electronic mailbox to allow the regulated community to request a Presidential Exemption to certain requirements of the Clean Air Act (CAA). Under Section...more

Cozen O'Connor

EPA Chemical Accident Safety Rule Challenge Ignites AG Conflict

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Sixteen Democratic AGs and the Harris County Attorney (Houston, Texas) have filed a motion to intervene in a lawsuit brought by industry groups challenging the EPA’s denial of their petition for reconsideration of the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing Grainger County Rock Crushing Facility

The Tennessee Air Pollution Control Board (“Board”) issued a February 28th Proposed Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) to Clear Development, LLC (“CD”) alleging violations of an air permit....more

Hanson Bridgett

Trucks, Trains, and Automobiles: Untangling the Status of California’s Vehicle Emission Waivers

Hanson Bridgett on

Vehicle manufacturers and operators in California are no stranger to complex regulations, with the California Air Resources Board’s (CARB) history of pioneering mobile emission regulations. ...more

Jones Day

EPA Puts "Holy Grail" of Climate Change in Crosshairs by Reconsidering Endangerment Finding and Other Regulations

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The U.S. Environmental Protection Agency ("EPA") announced an agenda to revisit numerous regulations addressing the emission of greenhouse gases ("GHGs")....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Title V/Clean Air Act: Harris County, Texas Petition to Object Filed Addressing Deer Park Chemical Manufacturing Facility

Harris County, Texas filed a March 10th Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) Administrator related to the Lubrizol Corporation’s Deer Park Plant (“Plant”)....more

Beveridge & Diamond PC

RMP Rulemaking Redux

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The U.S. Environmental Protection Agency’s (EPA) Risk Management Program (RMP) regulations, 40 C.F.R. Part 68, appear to be headed back to rulemaking. These much-debated provisions have been amended, rescinded, and...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Missouri Department of Natural Resources and St. Charles Retail Motor Fuel Facility Enter into Administrative...

The Missouri Department of Natural Resources (“MDNR”) and Mac’s Convenience Stores LLC (“Mac’s”) entered into a February 26th Administrative Order on Consent (“AOC”) addressing an alleged violation of the Missouri Air...more

K&L Gates LLP

Litigation Minute: Emerging Contaminants: What's on the Horizon?

K&L Gates LLP on

What You Need to Know in a Minute or Less - Emerging contaminants are synthetic or natural chemicals that have not been fully assessed from a health or risk perspective and are reportedly finding their way into consumer...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing Carthage Aluminum Extrusion Facility

The Tennessee Air Pollution Control Board issued a February 24th Technical Secretary’s Proposed Order and Assessment of Civil Penalty (“Order”) to Bonnell Aluminum, Inc. (“Bonnell”) addressing an alleged Air Permit violation....more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Mississippi Commission on Environmental Quality and Jonestown Cottonseed Oil Mill Owner Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Cottonseed Co Op Corporation (“CCC”) entered into an October 25th Agreed Order (“AO”) addressing alleged violations of a Title V Operating Permit. See Order No....more

Morrison & Foerster LLP

Advanced Clean Fleets Regulations No Longer in Force for Most Fleet Operators and Owners

In the face of the Trump administration’s hostility toward California’s Clean Air Act waivers in general, CARB withdrew its request to EPA for a waiver for the Advanced Clean Fleets (ACF) regulation on January 13, 2025....more

Beveridge & Diamond PC

Ten Strategies to Use When eNGOs FOIA EPA to Prepare for Citizen Suits

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Environmental non-governmental organizations (eNGOs) looking to develop citizen suits typically first mine publicly available compliance information companies must submit to state and federal environmental agencies. eNGOs...more

Troutman Pepper Locke

Texas BACT Is a Fact: The Texas Supreme Court Unpacks the Texas Clean Air Act’s BACT Definition

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Port Arthur Community Action Network (PACAN) v. Texas Commission on Environmental Quality et al. (Tex. Feb. 14, 2025) presented the Texas Supreme Court with a unique opportunity to provide defined guideposts to understand...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing Bradley County Ready Mix Concrete Facility

The Tennessee Air Pollution Control Board (“Board”) issued a January 22nd Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) to Smyrna Ready Mix Concrete, LLC (“Smyrna”) addressing an alleged violation of...more

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