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Keeping Track of the Trump Executive Actions

President Trump hit the ground running, issuing more executive orders, memoranda, and other actions on Inauguration Day than any previous president. Agencies are already working to implement those actions. Many of the actions...more

Are Plastics the New PFAS?

A recent conference led by Connecticut Attorney General (AG) William Tong discussed the alleged problems and potential solutions associated with plastics use and waste. Conference attendees included nearly two dozen...more

US EPA Warns of Fraudulent NOVs

Phishing scams can pop up anywhere, as evidenced by the U.S. Environmental Protection Agency (EPA) Office of Inspector General’s recent alert regarding fraudulent Notice of Violation letters (NOVs)....more

FERC Issues Notice of Proposed Rulemaking to Conform to EPA’s Recent CWA 401 Rule

At its May 23 open meeting, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (NOPR), proposing to establish a one-year “reasonable period of time” for certifying authorities to act on...more

Louisiana v. EPA: A Turning Point for Title VI and Environmental Justice?

At the end of January, a federal judge issued a ruling in a high-profile environmental justice case, Louisiana v. EPA, brought by Louisiana against the Environmental Protection Agency (EPA) and the U.S. Department of Justice...more

The Long-Awaited Lead and Copper Rule Improvements Have Arrived

On November 30, 2023, the U.S. Environmental Protection Agency (EPA) released its Proposed Lead and Copper Rule Improvements (LCRI). With this proposal, EPA aims to simplify and expand upon the 2021 Lead and Copper Rule...more

Air and Climate Report: January 2024

PM NAAQS: Already behind schedule is perhaps the mostly widely impactful rule change EPA has proposed in many years: a lowering of the national ambient air quality standard (NAAQS) for fine particulate matter (PM2.5). EPA has...more

Sackett v. EPA: A United (but Divided) Court Narrows CWA Scope

The U.S. Supreme Court just issued its long-awaited Sackett decision in which it significantly narrowed the scope of federal jurisdiction over “waters of the U.S.” under the Clean Water Act. Written by Justice Alito (with...more

EPA Advances PFAS Strategic Roadmap With Proposed Drinking Water Standards

On March 13, the Environmental Protection Agency (EPA) took the long-anticipated step of proposing maximum contaminant level goals (MCLGs), as well as individual maximum contaminant levels (MCLs), for six PFAS compounds under...more

Air & Climate Report: August 2022

In the world of air quality and climate change, summer 2022 began with a bang, as the Supreme Court finally spoke on the merits of EPA’s efforts to regulate carbon dioxide emissions from power plants under Section 111 of the...more

Environmental Groups Target Texas Air Permitting Program on Environmental Justice Grounds

On June 28, a coalition of 11 environmental groups petitioned the U.S. Environmental Protection Agency (EPA) under the Administrative Procedure Act and the Clean Air Act to address the alleged failure of Texas Commission for...more

EPA’s Clean Water Act Certification Proposal to Significantly Impact Hydropower Licensing

On June 1, the Environmental Protection Agency (EPA) released a pre-publication version of its proposal to re-write the Clean Water Act Section 401 rule (Certification Proposal), which, if finalized, is expected to have...more

Air & Climate Report: April 2022

With spring finally arriving, the long-expected avalanche of EPA activity on air issues has also arrived. In this second year of the Biden administration, following the pattern of prior administrations, we are starting to see...more

Court Decision to Vacate, Remand State Water Quality 401 Certification Rule

On October 21, the U.S. District Court for the Northern District of California vacated and remanded the U.S. Environmental Protection Agency’s (EPA) 2020 Clean Water Act Section 401 final rule (Certification Rule)....more

State Laws Provide New Pathways for Environmental Justice Claims

Environmental justice moved to the forefront of sociopolitical discussions in the country in 2020, receiving increased attention from politicians, community groups, and environmental agencies. Although this concept is not...more

The Fourth Circuit Weighs in on the Interpretation of CWA Section 401

There has been a longstanding debate about how to apply the one-year time limit on Clean Water Act Section 401 certification decisions. The D.C. Circuit court in Hoopa Valley Tribe v. FERC, 913 F.3d 1099 (D.C. Cir. 2019)...more

EPA Announces Reconsideration and Potential Revision of the Clean Water Act Section 401 Final Rule

On May 27, the Environmental Protection Agency (EPA) announced its intent to reconsider the Clean Water Act (CWA) Section 401 final rule issued by the Trump administration in June 2020 (Final Rule)....more

Environmental Justice to Play Significant Role in Air Permitting Process Under Biden Administration

Although environmental justice (EJ) is not a new concept in the context of air permitting, the Biden administration’s increased focus on identifying and addressing disproportionate environmental impacts on low-income...more

Second Circuit Enforces the Clean Water Act Section 401 One-Year Time Limit

On March 23, the Second Circuit issued its opinion in N.Y. Dep’t of Enviro. Conservation v. FERC, Case No. 19-1610 (i.e., the “Empire Pipeline” case). The case concerns the Federal Energy Regulatory Commission’s (FERC or...more

FERC Establishes Water Quality Certification Waiver Period for Natural Gas Projects

On March 18, 2021, FERC issued a Final Rule amending its regulations to establish a one-year period for states, tribes, or other certifying authorities (“Certifying Agencies”) to act on a Clean Water Act (“CWA”) Section 401...more

EPA Issues Long-Awaited Update to CWA Financial Capability Assessment

The COVID-19 pandemic has elevated fiscal concerns of water and sewer service providers, with many states imposing a moratorium on the collection of delinquent bills and the termination of service. The affordability of water...more

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