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Will EPA Apply the New 401 Certification Rule Retroactively to Pending Requests?

A filing in a California federal court indicates that EPA is planning to apply its new Clean Water Act section 401 certification rule to all certification requests, including those that are currently pending and that were...more

Steam Electric ELG Surprise in EPA’s Fall Regulatory Agenda

Better late than never, but on January 4, EPA published its Fall 2022 Unified Regulatory Agenda. The Reg Agenda includes a few new rulemaking initiatives and a number of schedule changes that were largely expected since EPA...more

401 Certification Proposal Hits the Street

EPA released a pre-publication version of its proposal to re-write the Clean Water Act 401 Certification Rule. The proposed re-write comes after the Northern District of California vacated EPA’s 2020 Certification Rule, which...more

Draft 401 Certification Rule Proposal Sent to OMB

On March 25, EPA sent a proposed Clean Water Act Section 401 Water Quality Certification rule to the Office of Management and Budget (OMB) for interagency review. Once cleared by OMB, the proposal will be published in the...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

EPA Issues 401 Q&A

On Friday, December 17, the Environmental Protection Agency (EPA) quietly issued a Q&A document concerning the vacatur of the 2020 Section 401 Certification Rule (2020 Rule). The Q&A confirms EPA’s view that the 1971...more

EPA and Army Corp’s Joint Section 401 Guidance Walks Back Regulatory Certainty

On August 19, EPA and the Army Corps of Engineers (Corps) issued a joint guidance document concerning implementation of EPA’s 2020 Water Quality Certification Rule. The agencies explain that the guidance applies specifically...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

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