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Functional Interdependence

K&L Gates LLP

Is The “Functional Interdependence” Test Dead?

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On May 30, 2014, the United States Court of Appeals for the D.C. Circuit vacated the Environmental Protection Agency’s (“EPA’s”) attempt to preserve an expansive view of what constitutes a single source of air emissions under...more

Moore & Van Allen PLLC

Natural Gas & Electricity Interdependency Update: FERC’s Third Quarterly Report on Gas-Electric Coordination

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Pursuant to the Federal Energy Regulatory Commission (“FERC”) November 15, 2012 Order Directing Further Conferences and Reports, the FERC Staff issued its third Gas-Electric Coordination Quarterly Report to the Commission ...more

K&L Gates LLP

EPA Will Continue to Apply the "Functional Interdependence" Test for Air Quality Source Determinations Outside of the Sixth...

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Introduction - On December 21, 2012, the U.S. Environmental Protection Agency (“EPA”) issued a new guidance memorandum (the “Page Memorandum”) on single source determinations for the oil and gas industry under the Clean...more

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