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U.S. Supreme Court Oral Arguments: Maritime Charters and the Specter of a New Permitting Regime

Earlier this month, the Supreme Court heard oral arguments in two important environmental cases—one that could change the approach to routine maritime charters and another that could introduce a potentially punishing...more

Two Decisions by Federal Appeals Courts Uphold Agency Deference

Two recent decisions from federal appeals courts illustrate once again that the courts will extend significant judicial deference to federal agencies that are grappling with controversial and complicated issues subject to...more

EPA and the Corps of Engineers Repeal the 2015 “Waters of the United States” Rule

The pre-publication version of the final rule to be promulgated by EPA and the U.S. Army Corps of Engineers (ACOE) to repeal the 2015 redefinition of the Clean Water Act’s term “Waters of the United States” which is the...more

Clean Water Act Cases: Of Irrigation and Navigability

The federal courts have recently decided two significant Clean Water Act (CWA) cases: State of Georgia, et al. v. Wheeler, where the US District Court for the Southern District of Georgia held that the 2015 rulemaking...more

DC Circuit Issues Two Important Clean Air Act and Administrative Law Decisions

The U.S. Court of Appeals or the District of Columbia has recently issued two important rulings on the Clean Air Act in particular and administrative law in general: California Communities Against Toxics, et al., v. EPA and...more

DC Circuit Rejects Challenge to EPA’s CERCLA Decision Regarding Hardrock Mining Industry

In a decision that will likely be welcomed by the electrical power, chemical manufacturing, and petroleum and coal products manufacturing industries, on July 19, 2019, the U.S. Court of Appeals for the District of Columbia...more

DC Circuit Upholds EPA’s Latest RCRA Recycling Rule

On July 2, 2019, the U.S. Court of Appeals for the District of Columbia Circuit decided the case of California Communities Against Toxics, et al. v. EPA. In this decision, the court rejected the latest petition to strike or...more

As Some States Use the Clean Water Act to Delay Energy Projects, EPA Issues New CWA 401 Guidance

In just the past few weeks, three states have used their Clean Water Act 401 authority to delay, for an indefinite period, FERC-authorized pipeline expansion projects....more

Recent Environmental Cases: Something in the Water, in the Air and in the Woods

State of Texas, et al. v. US EPA. The revised regulatory definition of “Waters of the U.S.” continues to generate litigation in the federal courts....more

Future Environmental Rulemaking Proceedings Listed in the Spring 2019 Unified Federal Agenda

The latest federal regulatory agenda has been released, which, among other matters, lists proposed and projected environmental regulatory proceedings being considered by different departments and agencies. ...more

Environmental Roundup – April 2019

Besides showers, this April brought a number of notable new environmental decisions issued by the federal courts. ...more

EPA Announces Decision to Retain Current Position on RCRA Regulation of Oil and Gas Production Wastes

After much study, EPA has decided against changing its current RCRA Subtitle D rules affecting the state regulation of oil and gas exploration & production waste. ...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

President Trump Issued Two New EOs on Energy Infrastructure and Federal Energy Policy

On April 10, President Trump issued two Executive Orders (EO) relating to the revision of some aspects of federal energy policy and development. 1. The first EO is very comprehensive, affecting many federal agencies and...more

Idaho Federal Court Rules Against Sacketts After SCOTUS Decided Judicial Review of an EPA Compliance Order was Permissible

In a decision released on March 31, in Sackett v. EPA, the U.S. District Court for Idaho held, without benefit of oral argument, that the Environmental Protection Agency’s (EPA) motion for summary judgment should be granted,...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

Eleventh Circuit Holds that EPA Superfund Remedial Actions are Usually Entitled to the FTCA “Discretionary Function” Exemption

An unusual Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, known also as Superfund) remedial action has resulted in a broad ruling that Environmental Protection Agency (EPA) remedial actions and...more

Selected Environmental Actions Posted on the Fall 2018 Unified Agenda of Regulatory and Deregulator Actions

The Office of Information and Regulatory Affairs, housed in the Office of Management and Budget, has issued the Fall 2018 Unified Agenda of Regulatory and Deregulatory Actions to be taken over the next several months by...more

World War II Government Procurement Contracts and CERCLA Liability

The U.S. Court of Appeals for the Federal Circuit’s July 18 ruling, in Shell Oil Company, et al., v. U.S., may have brought to an end a long-running dispute over the impact on World War II government procurement contracts on...more

DC Circuit Rules on Challenges to EPA’s 2015 Final Rule Governing Disposal of Coal Residuals Produced by Electric Companies and...

On August 21, the U.S. Court of Appeals for the District of Columbia decided the “coal combustions residuals” case: Utility Solid Waste Activities Group, et al. , v. EPA. This new Resource Conservation and Recovery Act (RCRA)...more

EPA’s Multi-Year Delay of Chemical Disaster Rule of 2017 Not Authorized Under CAA

On August 17, the U.S. Court of Appeals for the District of Columbia Circuit, in the case Air Alliance Houston, et al., v. EPA, vacated the Environmental Protection Agency’s (EPA) “Delay Rule.” ...more

2018 Update to EPA’s “Superfund Task Force Report”

The U.S. Environmental Protection Agency (EPA) recently released its Superfund Task Force Recommendations 2018 Update (the Update). ...more

Second Circuit Denies Petitions for Review of EPA’s Final Regulations to Establish Requirements for Cooling Water Intake...

On July 23, 2018, the U.S. Court of Appeals for the Second Circuit decided the case of Cooling Water Intake Structure Coalition v. EPA. Environmental conservation groups and industry associations petitioned for review of a...more

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