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Department of Justice Takes Historic Action to Prioritize Environmental Justice in Enforcement: What Does it All Mean and What is...

On May 5, 2022, Attorney General Merrick Garland announced key developments that would elevate environmental justice (EJ) as a key priority for the nation’s largest and most powerful enforcement agency. These historic...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

New York Proposes to Require Sustainability Reporting for the Fashion Industry

New York is poised to be the first state in the country to implement a fashion sustainability law. On January 7, 2022, Senator Alessandra Biaggi and Assembly Member Anna Kelles announced the Fashion Sustainability and Social...more

President Biden Announces New Methane Emissions Reduction Strategy

On November 2, 2021, President Biden released the U.S. Methane Emissions Reduction Action Plan (the “Plan”). The Plan, calling for substantial reductions in U.S. methane emissions, was announced in tandem with an...more

EPA Releases for Public Comment an Ambitious and Cross-Agency Climate Change and Environmental Justice Plan

Overview and Potential Action for Industry Stakeholders - On October 1, 2021, the Environmental Protection Agency (EPA or Agency) issued for public comment its Draft Strategic Plan to Address Climate Change and Advance...more

EPA Finalizes Rule Phasing Down Hydrofluorocarbons

The U.S. Environmental Protection Agency (EPA) published a final rule on October 5, 2021 establishing an allowance allocation and trading program for hydrofluorocarbons (HFCs). The rule implements certain key requirements...more

SEC Pushes for More Robust Climate Disclosures

The Securities and Exchange Commission (SEC) is poised to make good on its promise to ramp up enforcement efforts in relation to climate risk and environmental, social, and governance (ESG) disclosures. Last week, the SEC’s...more

Environmental Marketing Claims: Regulatory and Litigation Outlook

As consumers, investors, and other stakeholders are focused more than ever on the impacts of their purchasing and investment decisions, companies are seeking to convey information on the environmental attributes of their...more

EPA’s Multi-Sector General Permit for Industrial Stormwater Challenged in the Ninth Circuit —Plastics a Key Issue

Key Takeaways - • What happened? On July 1, 2021, the Center for Biological Diversity (the “Center”) petitioned the Ninth Circuit to review EPA’s issuance of the 2021 National Pollutant Discharge Elimination System...more

EPA Headquarters Prods Cleanup Programs on Enforcement to Strengthen EJ

On July 1, 2021, EPA’s Office of Enforcement and Compliance Assurance (OECA) issued a memorandum to all EPA Regional Offices urging the offices to increase cleanup program enforcement under the Comprehensive Environmental...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

California DTSC Finalizes Priority Product Listing of Carpets and Rugs Containing PFAS Triggering Reporting Requirements

On July 1, 2021, the California Department of Toxic Substances Control (DTSC) adopted a new “Priority Product” under the state’s Safer Consumer Products (SCP) Program: carpets and rugs containing perfluoroalkyl or...more

Maine Becomes First State to Sign Extended Producer Responsibility Law for Packaging, Other States with Plastics and Packaging...

Key Takeaways What is Happening? On July 13, 2021, Maine became the first state to sign Extended Producer Responsibility (EPR) legislation into law for plastics and packaging materials, and Oregon may soon follow. This...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

South Coast AQMD Adopts Warehouse Indirect Source Rule, First Reporting Months Away

On May 7, the South Coast Air Quality Management District (South Coast AQMD) adopted Rule 2305 (the “Rule”) aimed at regulating nitrogen oxide (NOx) and diesel particulate matter emissions associated with truck traffic at...more

Washington Joins Chorus of States with Major Environmental Justice Laws

Washington State has joined a growing number of states that have adopted keystone environmental justice laws. On May 17, 2021, Governor Jay Inslee signed the Healthy Environment for All (HEAL) Act, E2SSB 5141, into law. ...more

OMB Seeks Public Comments on Its Interim Social Cost of Carbon Metrics

The Office of Management and Budget (OMB) announced that it will solicit public comments on the interim social cost of carbon (SCC) metrics released in February by the Interagency Working Group on the Social Cost of...more

EPA Proposes Its First Rule Controlling HFCs Under the AIM Act

On May 3, 2021, EPA announced its first major climate change rule under the Biden Administration, proposing to phase down the manufacture and import of hydrofluorocarbons (HFCs), which are potent greenhouse gases. EPA...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

Washington State Plastics Bill Imposes Minimum Content Requirements on Many Household and Food Service Products

Key Takeaways What Is Happening? On April 21, 2021, the Washington State legislature passed a sweeping new minimum recycled content bill, SB5022, which creates recycled content minimums for some plastic products sold in...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

Reducing the Flood of Changes—EPA Issues a More Tempered Final 2021 Multi-Sector General Permit than Originally Proposed

Key Takeaways - • What Is Happening? The U.S. Environmental Protection Agency (EPA) finalized the 2021 National Pollutant Discharge Elimination System (NPDES) Multi-Sector General Permit (MSGP) for stormwater discharges...more

Biden Administration Rapidly Advances Climate Change Agenda

It’s no secret that President Biden plans to prioritize action on climate change. During his presidential campaign, Biden identified climate change as one of his top four priorities, and announced he would seek to put the...more

EPA Encourages Voluntary Self-Disclosure of Environmental Violations with Release of Updated Guidance

On February 5, 2021, EPA posted on its website updated Frequently Asked Questions (FAQs) in connection with its Audit Policy Program. EPA’s Audit Policy, first created in 1995, provides important incentives for regulated...more

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