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How Broad Is Too Broad? Supreme Court Considers Scope of NEPA

The U.S. Supreme Court is poised to address a circuit split over whether an agency doing an environmental review under the National Environmental Policy Act (NEPA) must consider effects beyond its regulatory jurisdiction,...more

California Climate Disclosures Remain on Schedule

Governor Newsom signs amended law, abandoning prior bid to provide additional time for implementation. Despite efforts by California Governor Gavin Newsom to provide more time for businesses to comply with the new...more

Big Data Meets Big Green: Data Centers and Carbon Removal Compete for Zero-Emission Energy

Artificial intelligence, data centers, carbon removal and zero-emission power may sound like a winning line (plus the Free Space) on a 2024 Buzzword Bingo card. But the concepts have come into dramatic real-world tension as...more

The Dunes Sagebrush Lizard Saga Continues: FWS Lists the Species as Endangered, Draws Congressional Response

On May 20, 2024, the U.S. Fish and Wildlife Service published a final rule listing the dunes sagebrush lizard as endangered under the Endangered Species Act. The listing does not include a designation of critical habitat....more

Final Rules Ramping Up Endangered Species Act Regulations Now in Effect

The rules address the listing process for critical species and habitat designations, as well as protections for threatened species. In a reversal, the rules also revise the ESA Section 7 interagency consultation process...more

U.S. Fish & Wildlife Service Rolls Out BGEPA General Permit, Streamlining Wind and Power Line Project Approvals

Beginning April 12, 2024, USFWS will offer a general permit application for incidental take of bald and golden eagles for wind energy and power line projects. The general permit option will provide an alternative to...more

DOI Aims to Modernize its “Inefficient and Inflexible” Type A Natural Resource Damages Assessment Regulations

The U.S. Department of the Interior (DOI) published a proposed rule aimed at modernizing and streamlining the “Type A” Natural Resource Damage Assessment (NRDA) regulations under the Comprehensive Environmental Response,...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

And Then There Were Three: Louisiana Granted Primacy over Class VI Wells

Louisiana is the third state granted authority to permit and regulate Class VI underground injection control (UIC) wells, marking a significant step forward for these projects. The Environmental Protection Agency (EPA)...more

Rulemaking to Modernize, Expand DOI’s “Type A” Natural Resource Damage Assessment Rules Expected Fall 2023

The U.S. Department of the Interior (DOI) anticipates proposing a new rule that would revise its “Type A” Natural Resource Damage Assessment (NRDA) regulations under the Comprehensive Environmental Response, Compensation, and...more

Seeking Certainty: Redefining “Waters of the United States”

The 2023 redefinition reinstates the “1986” framework defining the reach and scope of navigable waters. To determine if a regulated body of water is located on the landowner’s property, the agencies acknowledge these...more

EPA Tentatively Rejects the Center for Biological Diversity’s Petition to Regulate PVC as a Hazardous Waste

The EPA’s tentative determination signals the possibility of a future course reversal, and interested parties should consider making public comments, which could influence the outcome of the process. The U.S. Environmental...more

Blue Gold: Critical Water for Critical Energy Materials

As demand increases for low-carbon technologies to power the energy transition, the acquisition of critical materials—so-called given their integral role in the transition of energy activities—is becoming increasingly...more

Proposed Rule to Designate Two PFAS Chemicals as Hazardous Substances Stands to Up the Ante for Site Remediation

EPA released a pre-publication notice of its long-anticipated proposed rule to designate certain PFOS and PFOA as CERCLA (Superfund) hazardous substances. CERCLA hazardous substances designation would fulfill an important...more

Critical Materials for the Energy Transition: Of “Rare Earths” and Even Rarer Minerals

As the world pursues ambitious net-zero carbon emission goals, demand is soaring for the critical materials required for the technologies leading the energy transition. Lithium may be the most well-known of these inputs due...more

EPA Announces Stringent New Health Advisory Levels for Four PFAS Chemicals

New federal health advisory levels for per- and polyfluoroalkyl substances reflect added stringency of PFAS regulation and raise concerns about effective monitoring. The Biden Administration’s EPA continues its push to...more

Environmental Management Systems Bridge the Gap between ESG Goals and Implementation

An EMS is a straightforward and effective strategy to implement Environmental Social and Governance principles and enhance their performance. An EMS can help businesses ensure that their ESG programs are in compliance with...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

California Announces First Statewide Microplastics Strategy

Companies should consider taking proactive measures to avoid being blindsided by future microplastic-related laws. California’s adoption of the Statewide Microplastics Strategy is the first attempt by a U.S. state to...more

TCEQ Proposes Important Changes to Its Compliance History Rules

The Texas Commission on Environmental Quality (TCEQ) has proposed changes to compliance history rules that would authorize the Executive Director to unilaterally “reclassify” a facility’s compliance history in the wake of an...more

Biden EPA Doubles Down on Chemical Regulation with PFAS Strategic Roadmap

The agenda-setting document promises rulemakings across multiple EPA programs to expand the scope—and accelerate the pace—of PFAS regulation. The Biden administration continues the beat on PFAS regulation by releasing its...more

Houston, the "Energy Capital of the World," Positions to be the "Energy Transition Capital"

The Greater Houston Partnership’s new Energy Transition Strategy report makes an economic case that the Houston region is poised to lead the energy transition, articulating an industry-driven vision that builds on the City of...more

FDA Regulatory Approvals as the U.S. Emerges from the Immediate COVID-19 Emergency

Emergency Use Authorizations will play a role as the pandemic eases, but a transition to ordinary course approvals is underway. As long as the COVID-related emergency is deemed to exist, fast-tracked FDA regulatory...more

Regulatory Overview on PFAS in the United States

PFAS continues to be an area of focus for EPA and state agencies, as well as an ever-increasing litigation risk for companies that have manufactured, imported, processed, or otherwise used products including chemicals...more

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