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EPA Issues New Rules Regarding Response and Risk Management Plans

The Accidental Chemical Release Rules have an effective date of May 10, 2024, and includes a number of situations requiring compliance, generally by May 10, 2027. The new Clean Water Act facility response plan...more

Confronting Regulatory Fluidity in the Post-Maui and Post-Sackett World of Water Regulation

Both regulators and the regulated community must remain alert to accommodate the constantly changing regulatory scheme created in the post-Sackett world. The application of Maui and Sackett in recent months confirms the...more

Texas Commission on Environmental Quality Implements Changes to Compliance History Rules

Rule change may have impact on permitting, reporting and enforcement for sites dealing with emergencies. The Texas Commission on Environmental Quality (TCEQ) has adopted changes to compliance history rules that would...more

A Court-Side Seat: Permit Shields, Hurricane Harvey and the Decriminalization of “Incidental Taking”

This is a brief review of some of the significant environmental (and administrative law decisions) released the past few weeks. THE U.S. SUPREME COURT - On April 22, 2021, the Court decided two important administrative law...more

EPA Issues Interpretive Statement on Application of NPDES Permit System to Releases of Pollutants to Groundwater

On Tuesday, April 23, 2019, in a development of interest to practically anyone who operates a plant or business, EPA published its Interpretive Statement in the Federal Register....more

SCOTUS, Having Received Views of Solicitor General, Will Decide Whether CWA Regulates Indirect Discharge of Pollutants Into...

Prior to deciding whether to review an important February 1, 2018, U.S. Court of Appeals for the Ninth Circuit decision involving the jurisdictional reach of the Clean Water Act (CWA), Hawai’i Wildlife Fund, et al., v. County...more

Bills of Note Passed by the Last Congress (2019)

There were 442 bills passed by the 115th Congress and signed by the President. Most of these new laws have attracted very little attention, so it may be helpful to review a few of them....more

Solicitor General’s Views to Supreme Court on Two Circuit Court Rulings that Groundwater Can be Considered “Waters of the United...

On December 3, 2018, the U.S. Supreme Court invited the Solicitor’s views on the contested issues whether discharges to groundwater are subject to an he National Pollutant Discharge Elimination System (NPDES) permit, and...more

New CWA Citizen Suit on Liability for Groundwater Discharges

On September 30, the U.S. District Court for the District of Massachusetts issued a ruling dismissing claims that the operation of a municipal waste landfill violated the Clean Water Act (CWA) and Resource Conservation and...more

Fourth Circuit Issues New Ruling on Point Sources Under the CWA

The Clean Water Act (CWA) authorizes citizen suits to enforce the provisions of the law which requires a permit to discharge a pollutant from a point source into navigable waters. ...more

Companies Held Criminally and Vicariously Liable for Deliberate Violations of MARPOL

On May 7, the U.S. Court of Appeals for the Fourth Circuit affirmed the jury’s verdict that two shipping companies were guilty of criminal violations of the 1973 International Convention for the Prevention of Pollution from...more

Fourth Circuit Weighs In On Scope of CWA

On April 12, a significant Clean Water Act (CWA) ruling has been made by the U.S. Court of Appeals for the Fourth Circuit. The Fourth Circuit, in a split decision, held, in a case of first impression in this circuit, that the...more

Ninth Circuit Discusses “Point Sources” Under The CWA

On Friday, March 9, the U.S. Court of Appeals for the Ninth Circuit issued another significant ruling in a Clean Water Act (CWA) Citizen Suit case. Affirming the District Court, the Ninth Circuit held “pipes, ditches, and...more

New Ninth Circuit CWA Citizen Suit Decision On Indirect Discharges Into Navigable Waters Through Municipal Wastewater Effluent...

In the case of Hawaii Wildlife Fund, et al., v. County of Maui, decided on February 1, 2018, the U.S. Court of Appeals for the Ninth Circuit affirmed the decision of the U.S. District Court for Hawaii that the County of...more

First Circuit Concludes That EPA Did Not Fail To Perform Nondiscretionary Duties In Connection With TMDLs

On January 24, the U.S. Court of Appeals for the First Circuit decided the case of Conservation Law Foundation, Inc., v. Pruitt. The Pruitt case involves a consolidated appeal from the decisions of the U.S. District Courts in...more

Ninth Circuit Confirms That Defendant Had Fair Warning That His Conduct Violated The CWA

On November 27. the U.S. Court of Appeals for the Ninth Circuit decided an important Clean Water Act (CWA) jurisdictional case, United States. The Ninth Circuit unanimously affirmed the defendant’s criminal convictions for...more

CWA Citizen Suit Dismissed Where Plaintiffs Failed to Allege “Conveyance of Pollutants Into Navigable Waters

On April 20, the U.S. District Court for the District of South Carolina, Anderson Division, dismissed the plaintiffs’ Clean Water Act (CWA) Citizen Suit which alleged that the defendant pipeline operators had violated the CWA...more

WA Court Denies MSJs in CWA Citizen’s Suit Over Alleged Illegal Discharges of Coal and Coal Dust

A group of environmental organizations, headed by the Sierra Club, filed a Clean Water Act (CWA) citizen’s lawsuit against the BNSF Railway Company, alleging that the railroad, the only transporter of coal in Washington,...more

Supreme Court Reverses 9th Circuit on Logging Roads, Deferring to EPA on Its Industrial Stormwater Rule

On March 20, 2013, the U.S. Supreme Court held in a 7-1 decision that Clean Water Act permits are not required for stormwater runoff from logging roads. The decision in Decker v. Northwest Environmental Defense Center defers...more

The Supreme Court Reverses the 9th Circuit and Reaffirms Its Earlier Interpretation of ‘Discharge’ Under the Clean Water Act

On January 8, 2013, the U.S. Supreme Court held unanimously in L.A. County Flood Control District v. NRDC that the flow of polluted stormwater from an improved portion of a navigable waterway into an unimproved portion of...more

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