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CalRecycle Seeks Stakeholder Feedback on Single-Use Packaging EPR Program

Tomorrow, February 1, the California Department of Resources Recycling and Recovery (CalRecycle) will host a hybrid question and answer session to discuss the draft rulemaking on their extended producer responsibility (EPR)...more

California’s Transformational Single-Use Packaging EPR Law Moves Toward Implementation

Governor Gavin Newsom signed SB 54 on June 30, 2022, creating an extended producer responsibility (EPR) program and imposing some related prohibitions for certain single-use packaging and plastic single-use food service ware...more

EPA Ramps Up Climate Enforcement

Facilities operating across the country need to be prepared for increased climate-driven enforcement at all levels of federal government—especially at the U.S. Environmental Protection Agency (EPA). With EPA’s Climate...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

Washington State Proposes Sweeping Changes to Key Greenhouse Gas Regulation: Ecology’s Proposed Rule Targets Hydrofluorocarbons...

On July 13, 2023, the Washington State Department of Ecology (Ecology) published proposed amendments to Chapter 173-443 WAC, Hydrofluorocarbons (HFCs). Key provisions of the Proposed Rule include...more

Washington State Proposes Sweeping Changes to Key Greenhouse Gas Regulation

On July 13, 2023, the Washington State Department of Ecology (Ecology) published proposed amendments to Chapter 173-443 WAC, Hydrofluorocarbons (HFCs). Key provisions of the Proposed Rule include...more

D.C. Circuit Vacates Key Element in HFC Rules under AIM Act

A new D.C. Circuit opinion addressed the limits of non-delegation doctrine, upheld the U.S. Environmental Protection Agency’s (EPA) authority to regulate HFC/HFO blends, and struck down the agency’s authority to enact...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

Fishers' Livelihood Concerns Could Bring SCOTUS Sea Change for Environmental Law

The Supreme Court has agreed to hear a group of New Jersey herring fishers’ challenge to a long-standing key administrative law doctrine—the “Chevron doctrine.” It could be the next term’s most consequential case. The Chevron...more

EPA Finalizes SNAP Rule 25 and Lists New HFC Alternatives

On April 19, 2023, EPA finalized Rule 25 – Protection of Stratospheric Ozone: Listing of Substitutes under the Significant New Alternatives Policy Program in the Refrigeration & Air Conditioning and Fire Suppression Sectors....more

Six Tips for Companies Making “Climate-Smart Agriculture” Claims

Agriculture is on the very frontlines of our changing climate. Climate change directly affects many of the most fundamental aspects of agricultural production: the length of crop growing seasons; the ranges of insects, weeds,...more

Green Marketing Claims To Receive Increased Scrutiny

Green Marketing Updates in the European Union (EU) - Background - On March 22, 2023, the European Commission (Commission) published a Proposal for a Directive on Green Claims (Proposal). The Proposal is part of the EU's...more

DOJ Implements Nationwide “Voluntary Self-Disclosure” Program: All U.S. Attorneys’ Offices Instructed to Follow Updated Corporate...

The U.S. Department of Justice (DOJ) formally implemented a nationwide Voluntary Self-Disclosure policy (VSD policy) on February 22, 2023—effective immediately—that has been in the works for several years. The VSD policy...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

CalRecycle’s Recycling Revamp: Agency Poised to Amend California’s Recycling and Disposal Reporting System to Advance Statewide...

What's Happening? The California Department of Resources Recycling and Recovery (CalRecycle) published proposed regulations to amend the Recycling and Disposal Reporting System (RDRS) to increase the specificity of waste...more

DOJ Updates Corporate Criminal Enforcement Policy to Incentivize “Extraordinary Cooperation” with Prosecutors

The Department of Justice (DOJ) recently introduced the first significant revisions since 2017 to policies affecting all corporate matters handled by the DOJ’s Criminal Division. These policies aim to incentivize companies to...more

EPA Proposes “Technology Transition” Rule under the AIM Act to Further Restrict Use of HFCs

On December 15, 2022, the U.S. Environmental Protection Agency (EPA) published a proposed rule restricting the use of certain hydrofluorocarbons (HFCs) in aerosols, foams, refrigeration, air conditioning, and heat pump...more

FTC Invites Comments on “Green Guides” Refresh

Advertising claims about the environmental attributes of a product continue to become more important, and the Federal Trade Commission (FTC) is seeking to change how it regulates advertising. The FTC is seeking comment on a...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

Methane Emissions in the Spotlight at COP27: EPA Proposes for Comment Enhanced Methane Regulations and A Novel Super-Emitter...

Key Takeaways & Analysis - During the COP27 meeting of the UN Climate Change Convention, President Biden unveiled significant proposed enhancements to the Administration’s existing methane regulation program, including a...more

California Restricts PFAS in Clothing and Cosmetics; Governor Vetoes PFAS Reporting Bill

On September 29, 2022, California Governor Newsom signed California AB 1817, which bans the manufacture and sale of clothing and textile items containing PFAS, and AB 2771, which restricts PFAS in cosmetics. Both prohibitions...more

Climate Change, Environmental Justice, and Process Safety: EPA Proposes Risk Management Program Rule Amendments (Updated)

The U.S. Environmental Protection Agency (EPA) has proposed to further amend its Clean Air Act Risk Management Program (RMP) rules and has issued a proposed rule. 87 Fed. Reg. 53556 (August 31, 2022). The proposed rule would...more

Climate Change, Environmental Justice, and Process Safety: EPA Proposes Risk Management Program Rule Amendments

The U.S. Environmental Protection Agency (EPA) has proposed to further amend its Clean Air Act Risk Management Program (RMP) rules and has issued a proposed rule. 87 Fed. Reg. 53556 (August 31, 2022). The proposed rule would...more

EPA Increases Scrutiny of Self-Reporting Through the eDisclosure System

On June 30, 2022, the U.S. Environmental Protection Agency (EPA) Office of Inspector General (OIG) issued a report titled “Additional Internal Controls Would Improve the EPA’s System for Electronic Disclosure of Environmental...more

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