News & Analysis as of

Title V

Burr & Forman

New Title V Permitting Guidance from EPA

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In a move aimed to prioritize cooperative federalism and “ensure certainty for American businesses,” EPA has released new guidance outlining EPA’s expectations for Title V permit renewals, particularly in cases where the...more

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Title V/Clean Air Act: U.S. Environmental Protection Agency Order Denying Objection to Weld County, Colorado Oil and Natural Gas...

The United States Environmental Protection Agency (“EPA”) issued a January 6th Order Denying a petition objecting to the issuance of a Clean Air Act Title V Operating Permit (“Permit”) for Highpoint Operating Corporation...more

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Title V/Clean Air Act: U.S. Environmental Protection Agency Order Denying Objection to Adams County, Colorado Petroleum Products...

The United States Environmental Protection Agency (“EPA”) issued a January 6th Order denying a Petition objecting to the issuance of a Clean Air Act Title V Operating Permit (“Permit”) for the Holly Energy Partners, L.P.,...more

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Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Fort Smith Industrial Sand...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“ADEQ”) and Covia ISP, Inc. (“Covia”) entered into a March 11th Consent Administrative Order (“CAO”) addressing an alleged violation of a...more

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Air Enforcement: U.S. Environmental Protection Agency and La Crosse, Wisconsin Plastic Composites Manufacturing Facility Enter...

The United States Environmental Protection Agency (“EPA”) and FiberPro, Inc. (“FI”) entered into a January 22nd Consent Agreement and Final Order (“CAFO”) addressing alleged violations of a Clean Air Act Title V Permit. See...more

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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

Troutman Pepper Locke

D.C. Circuit Declines to Reconsider its Prior Order Restoring an Emergency Affirmative Defense for Emissions Violations Under the...

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On January 2, 2026, the D.C. Circuit declined to rehear en banc its prior order restoring the Clean Air Act’s (CAA) Title V affirmative defense to liability for excess emissions caused by emergency events. A group of...more

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Beef Production Facility/Citizen Suit Action: Center for Biological Diversity Judicial Action Seeking to Compel Title V Decision...

The Center for Biological Diversity (“CBD”) filed a Complaint in the District Court, Morgan County, Colorado against the Colorado Department of Public Health and Environment (“Colorado”) in regard to a beef processing...more

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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

Williams Mullen

Back from the Dead? D.C. Circuit Resurrects Emergency Affirmative Defense to Title V Air Permit Noncompliance

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Owners and operators of facilities subject to permitting under the Clean Air Act’s Title V permit program have cause for rejoicing. Title V permittees have just seen their fortunes improve, if only in a narrow way, with the...more

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Air Enforcement: Mississippi Commission on Environmental Quality and Smith County Sawmill Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Jack Batte and Sons Inc. (“JBS”) entered into a September 8th Agreed Order (“AO”) addressing an alleged violation of an Air Permit. See Order No. 7552 25....more

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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

Beveridge & Diamond PC

D.C. Circuit Reaffirms the Affirmative Defense for Emergency Events

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Key Takeaways What Happened? The U.S. Court of Appeals for the District of Columbia Circuit (D.C. Circuit) recently overturned the U.S. Environmental Protection Agency’s (EPA’s) 2023 final rule rescinding the affirmative...more

Pillsbury Winthrop Shaw Pittman LLP

D.C. Circuit Reverses EPA, Reinstating the Title V Affirmative Defense for Emergency Emissions Events

The D.C. Circuit held that EPA failed to adequately justify its rescission of the longstanding affirmative defense for emergency-related emissions exceedances under the Clean Air Act’s Title V program. The Court emphasized...more

Dickinson Wright

Key D.C. Circuit Decision Revives CAA Emergency Event Affirmative Defense

Dickinson Wright on

On September 5, 2025, the DC Circuit issued its opinion in SSM Litigation Group v. EPA, reversing EPA’s rescission of the longstanding emergency event affirmative defense under Title V of the Clean Air Act (“CAA”). The...more

Womble Bond Dickinson

Emergency Affirmative Defense for Title V Emissions Exceedances is Back

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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

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Air Enforcement: Tennessee Air Pollution Control Board Proposed Order Addressing South Pittsburg Iron Foundry

The Tennessee Air Pollution Control Board (“Board”) issued a July 31st Proposed Technical Secretary’s Order and Assessment of Civil Penalty (“Order”) to Lodge Manufacturing Company (“Lodge”) addressing alleged violations of a...more

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Air Enforcement: Mississippi Commission on Environmental Quality and Grenada County Lumber Company Enter into Agreed Order

The Mississippi Commission on Environmental Quality (“MCEQ”) and Hankins Lumber Company Inc. (“Hankins”) entered into an April 30th Agreed Order (“AO”) addressing alleged violations of a Title V Operating Permit. See Order...more

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Title V/Clean Air Act: Center for Biological Diversity Petition to Object Filed Addressing La Paz County, Arizona Gold Mine

The Center for Biological Diversity (“CBD”) filed a June 6th Petition to Object addressing the Bonanza Explorations’, Inc. Clean Air Act Title V Permit renewal.’ The Petition objects to the renewal of a Title V Operating...more

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

Title V/Clean Air Act: Center for Biological Diversity Petition to Object Filed Addressing Garfield County, Colorado Compressor...

The Center for Biological Diversity (“CBD”) filed a May 8th Clean Air Act Title V Petition to Object (“Petition”) before the United States Environmental Protection Agency (“EPA”) relating to Bargath, LLC for the Hyrup...more

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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

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Title V/Clean Air Act: Petition to Object Filed Addressing Scotia, California Biomass Facility

The Environmental Protection Information Center and Humboldt Coalition for Clean Energy (collectively, “EPIC”) filed a January 3rd Title V Petition to Object (“Petition”) before the United States Environmental Protection...more

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Air Enforcement: Alabama Department of Environmental Management and Mobile Sawmill Facility Enter into Consent Order

The Alabama Department of Environmental Management (“ADEM”) and Scotch and Gulf Lumber, LLC (“Scotch”) entered into a December 11th Consent Order (“CO”) addressing an alleged violation of a Clean Air Act Title V Major Source...more

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Title V/Clean Air Act: Sierra Club Petition to Object Filed Addressing Houston, Texas Refinery

The Sierra Club and three other environmental organizations filed the following document before the Administrator of the Environmental Protection Agency (“EPA”) on December 3rd: Petition to Object to the Title V Operating...more

Baker Botts L.L.P.

Fifth Circuit Issues Splintered En Banc Decision on Citizen Suit Standing

Baker Botts L.L.P. on

On December 11, 2024, the United States Court of Appeals for the Fifth Circuit issued an en banc opinion in Env’t Tex. Citizen Lobby, Inc. v. ExxonMobil Corp., No. 17-20545. The petition for rehearing requested en banc review...more

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