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EPA's New Strategic Civil-Criminal Enforcement Policy: Will Enhanced Coordination Lead to More Criminal Enforcement?

On 17 April 2024, the US Environmental Protection Agency (EPA) issued a new Strategic Civil-Criminal Enforcement Policy designed to improve collaboration between its civil and criminal enforcement offices, with the goal of...more

U.S. Supreme Court Issues Landmark Clean Water Act Decision, Significantly Narrowing the Scope of "Waters of the United States"...

It is rare for the U.S. Supreme Court to construe a statutory phrase on multiple occasions.  And yet now, for purposes of the federal Clean Water Act (CWA or the Act), it has rendered no less than four interpretations of the...more

EPA Releases New Tool to Analyze Costs of Complying With a State-Proposed No Discharge Zone, But It Carves Out Capital Costs From...

The U.S. Environmental Protection Agency (EPA) recently announced a new policy that it intends to use in considering costs imposed by No Discharge Zones (NDZs) under §  312(f)(3) of the Clean Water Act (CWA). Calling this...more

Industry Predictions for 2020 From the Maritime Professionals at K&L Gates

K&L Gates maritime professionals work at the intersection of the U.S. federal government and the maritime business. We asked some of them for their predictions about the year ahead regarding the Trump administration, the...more

Trump Administration Begins “Round 4” in the Battle Over Clean Water Act Jurisdiction

Last month the Trump Administration announced a proposed rule that would dramatically reduce the scope of federal authority under the Clean Water Act (“Act”). If finalized in its current form, the rule would eliminate federal...more

Less Waste, More Recycling - The D.C. Circuit Cleans Up EPA’s Definition of Solid Waste

The U.S. Court of Appeals for the D.C. Circuit recently issued a decision that may be of interest to recyclers and others who generate or handle materials for recycling and reclamation. On July 7, 2017, in American Petroleum...more

A Not-So-Silver Lining: The Ninth Circuit Vacates EPA’s Conditional Approval of a Nanosilver Pesticide Used in Manufacturing...

Do you manufacture, distribute or sell products such as trash cans, cell phones, computers, furniture, watch bands, uniforms, sportswear, or office supplies that have labels claiming that the products are “antimicrobial” or...more

Climate Change Hits EPA: 30 Pending Regulations Frozen

In accordance with direction from the Trump administration, the U.S. Environmental Protection Agency (“EPA”) has published a final rulemaking delaying the effective date of 30 pending regulations until at least March 21,...more

Upping the Ante: DOJ Prosecuting OSHA Cases as Environmental Crimes

In December of 2015 the Department of Justice (“DOJ”)and the Department of Labor jointly announced an expansion of the “Worker Endangerment Initiative” to address violations of worker safety and environmental laws. In...more

EPA Announces Timeline for VGP 3.0

The Environmental Protection Agency’s (EPA) primary method of regulating ballast water and other discharges is the Vessel General Permit (VGP). Under its Clean Water Act authority, the EPA established the VGP to impose...more

Changes to Confidential Business Information Disclosure Under the Reformed Toxic Substances Control Act

This client alert is the fourth in a series that discusses the significant changes instituted by the passage of a new federal Toxic Substance Control Act (TSCA). The first alert addressed broadly the law’s myriad of changes....more

An Air of Change in CERCLA Liability? Pakootas v. Teck Cominco and CERCLA’s Federal Permit Shield

A case recently argued before the Ninth Circuit, Pakootas v. Teck Cominco Metals, Ltd., 9th Cir., No. 15-35228, could pave the way for a new theory of liability for parties who release air emissions during the course of...more

Clean Water Rule Stayed Nationwide

On October 9, 2015, the United States Court of Appeals for the Sixth Circuit issued a stay of the Obama Administration’s new rule defining the scope of federal jurisdiction under the Clean Water Act. The stay postpones...more

EPA and the Army Corps Issue Final Clean Water Rule, but Does This New “Line in the Water” Clarify, Expand or Narrow Clean Water...

On May 27, 2015, the United States Environmental Protection Agency (“EPA”) and Army Corps of Engineers (“Corps”) jointly released a final rule (the “Clean Water Rule”) redefining the scope of their shared jurisdiction under...more

Supreme Court “Not Willing to Stand on the Dock and Wave Goodbye” as EPA Explores How It Can Regulate Greenhouse Gases from Every...

In 2007, the Supreme Court told the U.S. Environmental Protection Agency (EPA) it was wrong to conclude that it lacked the authority to regulate greenhouse gases (GHGs) emitted from vehicles, because GHGs are an “air...more

Facing Two Strikes, EPA Gets a Hit: Supreme Court Upholds EPA Cross-State Air Pollution Rule

Two years ago, we reported that the D.C. Circuit vacated and remanded the U.S. Environmental Protection Agency’s (“EPA”) second attempt at regulation of air pollution crossing state borders. Facing two strikes, EPA swung for...more

Federal Appellate Court Stays Initial Date for Meeting New Ballast Water Discharge Limits – But Only for Canadian Shipowners...

On April 9, 2014, the United States Court of Appeals for the Second Circuit granted a stay of the January 1, 2014 deadline for installation of ballast water treatment technology required by the U.S. Environmental Protection...more

EPA and the Army Corps Propose Rules Expanding Clean Water Act Jurisdiction, Potentially Affecting Everyone Who Uses Lands Where...

On March 25, 2014, the United States Environmental Protection Agency (“EPA”) and Army Corps of Engineers (“Corps”) jointly released a long-awaited proposed rulemaking that would redefine the scope of their shared jurisdiction...more

EPA and Coast Guard Disagree on How to Address Industry Obligations to Meet January 1, 2014 Implementation Deadline For New...

Under the National Invasive Species Act of 1996, the U.S. Coast Guard regulates ballast water discharged from vessels by requiring installation of certain technologies that treat ballast water prior to discharge. The...more

EPA Issues 2013 Vessel General Permit

On March 28, 2013, the United States Environmental Protection Agency (EPA) published a new Clean Water Act Vessel General Permit (2013 VGP) that regulates discharges from commercial vessels greater than or equal to 79 feet in...more

EPA Proposes Revisions to the Renewable Fuel Program to Prevent Fraud and Protect Innocent Traders in Renewable Identification...

Introduction - In 2007, the Environmental Protection Agency (“EPA”) established a program for trading renewable fuel credits (called “Renewable Identification Numbers” or “RINs”) for companies that were unable to produce...more

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