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Environmental Developments to Watch in Washington State - 2025 Mid-Year Update

Washington State’s most recent legislative session brought a flurry of environmental activity, with lawmakers advancing measures on climate disclosure, chemical regulation, clean energy infrastructure, and, after several...more

Oregon Pursues Listing PFOA and PFOS as Hazardous Substances under State Cleanup Law

Last month, the Oregon Department of Environmental Quality (DEQ) announced a rulemaking process to list perflouorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) as hazardous substances under the Oregon Cleanup...more

FWS Issues Streamlined General Permits for Incidental Take of Eagles

On February 12, 2024, the United States Fish and Wildlife Service (FWS) published a final rule that created several long-awaited general permits under the Bald and Golden Eagle Protection Act (Eagle Act) to authorize...more

Pacific Northwest Climate Law Update: Recent Developments Cloud the Future of Oregon and Washington Climate Programs

Two developments toward the end of 2023 have clouded the future of climate policy in the Pacific Northwest. First, on November 21, 2023, opponents of Washington’s Climate Commitment Act (CCA) submitted more than 400,000...more

Appeals Court Upholds Penalty Against Members of LLC that Owned Landfill for Violations of Oregon’s Landfill Closure Law

A long-running dispute over a substantial civil penalty issued by the Oregon Department of Environmental Quality (DEQ) for violations of Oregon’s landfill closure requirements continued with the Oregon Court of Appeals’...more

Incidental Take of Migratory Birds Once Again a Federal Crime; FWS Considering New Permitting Program

After a brief hiatus, incidental take of migratory birds will again be a federal crime beginning December 3, 2021. Less than 10 months after instituting a final rule declaring that incidental take of birds is not subject to...more

Supreme Court Clarifies That Only CERCLA Settlements Trigger Contribution Claims

On May 24, the Supreme Court weighed in on an issue that for decades has bedeviled litigants under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA): When can potentially responsible parties...more

Department of the Interior Seeks to Withdraw Migratory Bird Treaty Act Liability Rule

In a proposed rule published May 7, 2021, the Biden Administration seeks to withdraw the Trump Administration’s Migratory Bird Treaty Act (MBTA) liability rule. The MBTA liability rule was published as a final rule on January...more

Migratory Bird Treaty Act Liability Rule Looks to Be Short-Lived

The Biden Administration is moving quickly to undo the Trump Administration’s Migratory Bird Treaty Act (MBTA) liability rule. Published as a final rule on January 7, 2021, this rule for the first time supplied a uniform...more

Supreme Court to Decide Superfund Case with Significant Implications Regarding the Timing of CERCLA Contribution Claims

The U.S. Supreme Court will once again wade into the scope and meaning of CERCLA, granting Guam’s petition for certiorari in Territory of Guam v. United States, No. 20-382, petition for cert. granted (U.S. Jan. 8, 2021). This...more

Migratory Bird Treaty Act Liability Rule Finally Is Here, But For How Long?

In a long-unfolding saga, on January 7, 2021, the U.S. Fish and Wildlife Service (FWS) published its final rule that will at long last establish a clear regulatory definition of the scope of liability under the Migratory Bird...more

Tenth Circuit Upholds OSHA Interpretations on Scope of PSM Standard

On October 27, 2020, the Tenth Circuit upheld a series of OSHA citations that were issued to an oil refining company following a fatal boiler explosion. In doing so, the Tenth Circuit upheld OSHA interpretations that...more

Washington Continues Wide-Ranging Efforts to Address PFAS With Release of the Draft Chemical Action Plan

The Department of Ecology (Ecology) and the Department of Health have jointly released the Draft Chemical Action Plan (CAP) for per- and polyfluoroalkyl substances (PFAS). The Draft CAP will be available for public comment...more

Federal Court Rejects Interior Department Interpretation Limiting Migratory Bird Treaty Act Liability For Intentional Acts

The Trump Administration’s efforts to clarify the scope of liability under the Migratory Bird Treaty Act (MBTA) suffered a setback when the U.S. District Court for the Southern District of New York concluded that the statute...more

Government Proposes to Codify Limits on Migratory Bird Treaty Act Liability

The U.S. Fish and Wildlife Service (the “Service”) on February 3, 2020 issued a proposed rule that for the first time would supply a uniform regulatory definition of the scope of liability under the Migratory Bird Treaty Act...more

Who Gets to Decide What an Agency Meant? U.S. Supreme Court Places Limits on Agency Deference

In a 5-4 decision, the United States Supreme Court has ruled that governmental agencies are still entitled to deference in interpreting their own regulations—but only where those regulations are “genuinely ambiguous.” Kisor...more

Not So Cooperative Federalism? Washington Sues EPA Over Reversal in Long Running Human Health Criteria Saga

On June 6, Washington filed a lawsuit challenging EPA’s May 10, 2019, decision to reverse its 2016 disapproval of Washington’s proposed Human Health Criteria (HHC) under the Clean Water Act (CWA). The lawsuit represents the...more

Florida Federal Court Denies Proposed 60-Square-Mile Class Area in Environmental Contamination Action

A Florida federal district court recently denied a petition for class certification by a group of property owners that allegedly suffered health risks and diminished property values due to contamination at Pratt & Whitney’s...more

NGOs Challenge Department of Interior’s New Interpretation of “Incidental Take” Liability Under Migratory Bird Treaty Act

National environmental groups recently filed a pair of new lawsuits in New York federal district court seeking to expand the scope of liability for “incidental take” under the Migratory Bird Treaty Act (“MBTA”). The...more

Montana Supreme Court Undercuts CERCLA, Permits Property Owners to Pursue Restoration Damages Claim

In an opinion tilting against the weight of precedent elsewhere, the Montana Supreme Court held that private landowners could pursue common-law claims to clean-up their properties beyond what EPA required in its selected...more

Second Circuit Affirms Dismissal of Water Contamination Action as Untimely

In a decision addressing the unique accrual issues arising in a groundwater contamination action, the Second Circuit affirmed a decision dismissing the Bethpage Water District’s (the “District”) action as untimely. Bethpage...more

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