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Litigation Targeting Plastics Manufacturers

As we continue to see a rise in litigation related to plastic pollution, plastic manufacturers must remain prepared and should carefully follow the different kinds of claims to see which ones are ultimately more successful....more

One of EPA’s First Attempts to Implement San Franscico v. EPA: Modifications to EPA’s 2022 Construction General Permit

Key Takeaways - What Happened? The U.S. Environmental Protection Agency (EPA) issued a final modification to its 2022 Construction General Permit (CGP) to expand the list of areas eligible for coverage to include...more

Environmental Enforcement Update: What to Expect In the Second Trump Administration

We anticipate President Trump’s upcoming term will usher in significant shifts in U.S. environmental enforcement priorities and practices. Beveridge & Diamond has helped clients navigate every change in administration since...more

Ecology Proposes Significant—And Legally Vulnerable—Changes to Washington’s Industrial Stormwater General Permit

Key Takeaways - What is Happening? The Washington State Department of Ecology (Ecology) published for public comment its proposed 2025 Industrial Stormwater General Permit (ISGP), which authorizes the discharge of...more

EPA Issues Final Rulemaking on Clean Water Act Hazardous Substance Facility Response Plans

Key Takeaways - • What Is Happening? On March 14, 2024, The U.S. Environmental Protection Agency (EPA) signed a final rule requiring certain facilities to develop Facility Response Plans (FRPs) for a potential worst-case...more

Oil Pollution Act: Tips for Spill Response, Compliance, and Enforcement

Oil spills commonly occur when least expected and, even in smaller quantities can significantly disrupt business operations and create risks for enforcement and/or litigation. It’s important that companies are prepared and...more

The Biden Boomerang Effect Reaches Clean Water Act Section 401: EPA Reverses Trump-Era Rules that Reduced State Certification...

On September 15, 2023, the U.S. Environmental Protection Agency (EPA) issued its final rule governing water quality certifications under Section 401 of the Clean Water Act (CWA). Section 401 requires the applicant for a...more

Supreme Court Narrows CWA Jurisdiction Over Waters of the U.S.

On May 25, the U.S. Supreme Court issued its long-awaited decision in Sackett v. EPA, No. 21-454, holding that Clean Water Act (CWA) jurisdiction extends to wetlands only if they have a continuous surface connection to...more

Ninth Circuit Causes a Ripple

On February 21, 2023, the U.S. Court of Appeals for the Ninth Circuit (Ninth Circuit) issued the latest in a series of opinions involving the Trump Administration’s rule interpreting Section 401 of the Clean Water Act (CWA)....more

Washington Supreme Court Affirms Ecology’s Authority to Bypass Rulemaking When Requiring New PCB Sampling Methods Under CWA...

The Washington State Supreme Court agreed with the Department of Ecology in a dispute over whether Ecology should have followed notice and comment rulemaking procedures when adding two new controversial test methods for...more

Tribal Treaty Rights Take Center Stage in Two Landmark Federal Water Quality Actions

Key Takeaways - • What Happened? The U.S. Environmental Protection Agency (EPA) is seeking to increase the protection of tribal treaty rights through water quality standards. First, EPA issued a final rule re-establishing...more

EPA Expands Clean Water Act Spill Response Planning to Hazardous Substances

Key Takeaways - • What Is Happening? The U.S. Environmental Protection Agency (EPA) published a proposed rule requiring certain facilities to prepare Facility Response Plans (FRPs) for responding to worst case discharges...more

Supreme Court Wades Into Troubled Waters, Brings Trump Administration State Water Quality Certification Rule Back to Life

The U.S. Supreme Court on April 6, 2022, issued an emergency order reinstating the Trump Administration’s rule governing Section 401 of the Clean Water Act. The rule imposes limits on the timing and scope of a State or...more

Fourth Circuit Weighs In On Rules For Clean Water Act’s One-Year Deadline for State Water Quality Certifications for Federal...

On July 2, 2021, the U.S. Court of Appeals for the Fourth Circuit waded into the controversy surrounding proper interpretation of the one-year deadline for state action contained in Section 401 of the Clean Water Act. Its...more

New Interpretation of Shot Clock Rules? Fourth Circuit Weighs In On Clean Water Act’s One Year Deadline for State Water Quality...

On July 2, 2021, the U.S. Court of Appeals for the Fourth Circuit waded into the controversy surrounding proper interpretation of the one-year deadline for state action contained in Section 401 of the Clean Water Act. Its...more

Oregon Adopts a Significantly Modified (and Legally Vulnerable) Industrial Stormwater General Permit

Oregon Department of Environmental Quality’s (DEQ’s) policy and rulemaking board adopted rules renewing Oregon’s National Pollutant Discharge Elimination System (NPDES) Stormwater Discharge General Permit No. 1200-Z (1200-Z...more

FERC Adopts Final Rule Formalizing One-Year Deadline for States To Issue Clean Water Act Certifications; Second Circuit Affirms...

On March 18, 2021, the Federal Energy Regulatory Commission (FERC) adopted a Final Rule requiring state agencies to issue Clean Water Act (CWA) Section 401 water quality certificates within one year of receiving a request or...more

FERC Proposes One-Year Deadline for States to Issue Clean Water Act Certifications

Acting in response to a Trump Administration Executive Order instructing federal agencies to reduce regulatory uncertainties and expedite construction of energy infrastructure, the Federal Energy Regulatory Commission (FERC)...more

Department of Justice Issues New Guidance Limiting Federal Clean Water Act Civil Enforcement Overfiling of State Actions

On July 27, 2020, U.S. Department of Justice (DOJ) Assistant Attorney General (AAG) Jeffrey Bossert Clark issued a memorandum setting forth limitations to federal civil enforcement discretion concerning certain Clean Water...more

EPA Tackles Controversial Clean Water Act Certification Requirements

The U.S. Environmental Protection Agency (EPA) published a final rule to interpret the requirements for water quality certification under section 401 of the Clean Water Act. This Section grants states and approved tribes the...more

EPA Finalizes Removal of Water Quality Standards Despite Pending Washington Lawsuit

In what may be the beginning of the final chapter of a long-running saga over water quality standards in Washington State (Washington), the U.S. Environmental Protection Agency (EPA) has approved the removal of federal human...more

EPA Releases 2020 Multi-Sector General Permit for Comment

The U.S. Environmental Protection Agency (EPA) published for public comment its proposed 2020 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP), which authorizes stormwater discharges...more

New WOTUS Rule Clarifies Clean Water Act Jurisdiction, Awaits Litigation

On January 23, 2020, the U.S. Environmental Protection and U.S. Army Corps of Engineers finalized a long-awaited new rule redefining the term “Waters of the United States” (WOTUS) under the Clean Water Act (CWA). The Agencies...more

Ninth Circuit Orders EPA to Develop Total Maximum Daily Loads for Temperature on the Columbia and Snake Rivers

On December 20, 2019, the U.S. Court of Appeals for the Ninth Circuit ordered the Environmental Protection Agency (EPA) to issue “long overdue” total maximum daily loads (TMDLs) for water temperature for the Columbia and...more

EPA Proposed Regulations Aim to Further Clarify CWA Section 401 Certification Reviews

On August 8, 2019, the U.S. Environmental Protection Agency (EPA) published a proposed rule to revise its regulations (40 C.F.R. Part 121) implementing Section 401 of the Clean Water Act (CWA), 33 U.S.C. § 1341. The proposed...more

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