News & Analysis as of

State Implementation Plans (SIPs)

Vorys, Sater, Seymour and Pease LLP

U.S. EPA Issues Direct Final Rule Reinstating Title V Affirmative Defense Provisions

On June 1, 2026, U.S. EPA issued a direct final rule rescinding a 2023 rule that eliminated the Affirmative Defense provisions from state and federal Title V operating permit programs (the “Direct Final Rule”)....more

ArentFox Schiff

EPA Reinstates Title V Emergency Affirmative Defense Provision

ArentFox Schiff on

On May 28, the US Environmental Protection Agency (EPA) issued a final rule that reinstates the longstanding emergency affirmative defense provision under the Clean Air Act’s Title V operating permit programs (the “Emergency...more

Beveridge & Diamond PC

Indirect Sources Rules in Colorado: Denver Regional Authority Moves Forward to Regulate Four Key Sectors

Key Takeaways - Denver’s Regional Air Quality Council (RAQC) is developing Indirect Source Rules (ISRs) to curb emissions from trucks and passenger vehicles by regulating facilities such as warehouses, entertainment...more

Vinson & Elkins LLP

Build Now, Permit Later? What EPA’s Air Permitting Proposal Means for Data Centers and Major Projects

Vinson & Elkins LLP on

Last fall, the Environmental Protection Agency (“EPA”) gave project developers a valuable thing in Clean Air Act permitting: a usable bright line....more

Vorys, Sater, Seymour and Pease LLP

U.S. EPA Proposed Redesignation of Cleveland Area to Attainment for Ozone NAAQS

On April 10, 2026, U.S. EPA proposed to redesignate the Cleveland, Ohio area to attainment for the 2015 ozone National Ambient Air Quality Standards (NAAQS) (the Proposed Rule) – an action that, if finalized, will facilitate...more

Snell & Wilmer

No “Serious” Upgrade: EPA Decision Keeps Maricopa in the “Moderate” Lane

Snell & Wilmer on

On March 23, 2026, in a decision consequential to regulated Maricopa County businesses and those looking to relocate or expand, the U.S. Environmental Protection Agency (EPA) declined to reclassify the Phoenix-Mesa ozone...more

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

Title V/Dual Fuel Combustion Turbines: Sierra Club Petition Objecting to Georgia Environmental Protection Division Issuance of...

Sierra Club and Adrien Webber (collectively, “Sierra Club”) filed a Petition for Hearing (“Petition”) in the Office of State Administrative Hearings appealing the issuance of a Title V Air Quality Permit amendment...more

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

Regional Haze/Second Implementation Period: National Parks Conservation Association/Colorado Attorney General Challenge U.S....

The National Parks Conservation Association and Sierra Club (collectively, “NPCA”) and the Colorado Attorney General (“AG”) filed separate Petitions before the United States Court of Appeals for the 10th Circuit challenging...more

Goldberg Segalla

Another AI Mining Power Permit, Another Lawsuit

Goldberg Segalla on

A little over a month ago, the Georgia Environmental Protection Division (EPD) approved permits for four new dual-fuel combustion turbines to be used at Georgia Power’s Plant Bowen, a huge coal-fired facility located just a...more

Vorys, Sater, Seymour and Pease LLP

U.S. EPA Proposed Determination: Cleveland Area Attains Ozone NAAQS

On February 27, 2026, U.S. EPA issued a proposed rule that, if finalized, would position the Cleveland, Ohio Nonattainment Area for redesignation to attainment of the 2015 ozone National Ambient Air Quality Standard (NAAQS)....more

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

Regional Haze/Second Implementation Period: U.S. Environmental Protection Agency Guidance Memorandum

The United States Environmental Protection Agency (“EPA”) issued a memorandum on February 19th addressing the Clean Air Act Regional Haze program styled: Update to Guidance on Regional Haze State Implementation Plans for...more

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

Title V/Clean Air Act: Environmental Law & Policy Center Petition to Object Filed Addressing Whiting, Indiana Refinery

The Environmental Law & Policy Center (“ELPC”)  along with 5 other organizations filed a Title V Petition to Object (“Petition”) before the United State Environmental Protection Agency (“EPA”) related to the BP Products North...more

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

Title V/Clean Air Act: Harris County, Texas Attorney's Office Petition to Object Filed Addressing Baytown Olefins Plant

The Harris County, Texas Attorney’s Office (“Harris County”) filed a Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) related to the ExxonMobil Corporation’s Baytown...more

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

Regional Haze/Advance Notice of Proposed Rulemaking: Arkansas and 17 other State Attorney Generals' Comments on EPA's Solicitation...

The State of Arkansas and 17 other Attorney Generals filed December 1st Comments addressing an October 2nd Advanced Notice of Proposed Rulemaking (“ANPR”) issued by EPA styled: Visibility Protection: Regional Haze State...more

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

Regional Haze/Advance Notice of Proposed Rulemaking: Environmental Organizations' Comments on EPA Solicitation of Potential...

The Environmental Defense Fund and eleven other environmental organizations filed December 1st Comments addressing an October 2nd Advanced Notice of Proposed Rulemaking (“ANPR”) issued by EPA styled: Visibility Protection:...more

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

Alabama Regional Haze SIP Plan for the Second Planning Period: Southern Environmental Law Center and Other Environmental...

Six environmental organizations submitted November 7th comments to the Alabama Department of Environmental Management  (“ADEM”) on the State’s Regional Haze State Implementation Plan (“SIP”) for the Second Planning Period....more

Goldberg Segalla

Fighting Fire with Fire: EPA Issues Guidance Promoting Prescribed Fires to Help Prevent Catastrophic Wildfires

Goldberg Segalla on

Last week, the Environmental Protection Agency issued its “Policy on Provisions to Allow Wildland Prescribed Fire in Clean Air Act State Implementation Plans” in accordance with  Section 4 (Strengthening Wildfire Mitigation)...more

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

Title V/Clean Air Act: Petition to Object Filed Addressing Other Basic Organic Chemical Manufacturing Facility in Harris County,...

Harris County, Texas filed a Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) related to Lubrizol Corp. (“Lubrizol”) Deer Park Plant. See Title V Air Operating Permit...more

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

Citizen Suit Action/Clean Air Act: Sierra Club Judicial Action Alleging U.S. Environmental Protection Agency Failure to Address...

The Sierra Club and other organizations filed in the United States District Court for the Northern District of California (“Court”) a September 2nd Complaint for Injunctive and Declaratory Relief (“Complaint”) against the...more

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

Evaluation of the EPA's Oversight of State and Local Ambient Air Monitoring Operating Schedules: U.S. EPA Office of Inspector...

The United States Environmental Protection Agency (“EPA”) Office of Inspector General (“OIG”) issued on September 15th a report titled: Evaluation of the EPA’s Oversight of State and Local Ambient Air Monitoring Operating...more

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

How the Clean Air Act Impacts Building Necessary Infrastructure/Onshoring American Innovation: Subcommittee on Environment/U.S....

The Subcommittee on Environment of the United States House of Representatives Energy and Commerce Committee held a hearing on June 11, titled: Short-Circuiting Progress: How the Clean Air Act Impacts Building Necessary...more

Womble Bond Dickinson

Emergency Affirmative Defense for Title V Emissions Exceedances is Back

Womble Bond Dickinson on

On Friday, the D.C. Circuit reinstated the affirmative defense for emergency situations resulting in exceedances of emission limitations in Clean Air Act Title V operating permits. That defense, available in the Title V...more

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

Arkansas Ambient Air Monitoring Network: Annual Network Plan for 2025-2026

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) submitted on August 6th to the United States Environmental Protection Agency (“EPA”) a document titled: ARKANSAS AMBIENT AIR...more

Holland & Knight LLP

EPA Proposes Significant Budget Reduction for Fiscal Year 2026

Holland & Knight LLP on

The U.S. Environmental Protection Agency's (EPA) budget proposal for fiscal year (FY) 2026 fundamentally reimagines the federal government's role in environmental policy and regulation. If enacted by Congress, EPA's budget...more

Holland & Hart LLP

EPA Reclassifies the Northern Wasatch Front and Uinta Basin Ozone Nonattainment Areas

Holland & Hart LLP on

EPA recently redesignated the Northern Wasatch Front and the Uinta Basin ozone nonattainment areas based on data demonstrating that the areas failed to meet the 2015 ozone National Ambient Air Quality Standard (NAAQS) by...more

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