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Steam Electric ELG Surprise in EPA’s Fall Regulatory Agenda

Better late than never, but on January 4, EPA published its Fall 2022 Unified Regulatory Agenda. The Reg Agenda includes a few new rulemaking initiatives and a number of schedule changes that were largely expected since EPA...more

Slow EPA Approvals Impair State Carbon Storage Plans

The Biden administration has enormous climate and carbon management goals — which rightfully include the geologic sequestration of carbon dioxide as a core part of its climate adaptation strategy. Originally published in...more

H2-OWOW! – A Reflective Conversation with John Goodin, Former Director of EPA’s Office of Wetlands, Oceans, and Watersheds –... [Audio]

John Goodin takes a break from his recent retirement to share invaluable insights with Dave and Anna from his 32-year career in EPA’s Office of Water. John talks about the long-running “waters of the United States”...more

Reflections on Sackett - Reflections on Water Podcast [Audio]

Dave Ross and Anna Wildeman provide high-level reactions to the Supreme Court's oral arguments in the Sackett v. EPA case, the latest legal battle in a long-running dispute over the meaning of the phrase "waters of the United...more

PFAS in Focus: Wastewater Utility Perspectives From Jay Hoskins, Metropolitan St. Louis Sewer District - Reflections on Water... [Audio]

Anna and Dave continue their Missouri Water Seminar PFAS miniseries with Assistant Director of Engineering-Environmental Compliance Jay Hoskins of the Metropolitan St. Louis Sewer District. Jay, Anna, and Dave discuss...more

EPA UIC Class VI Program Administration Creates Potential Weak Link in Climate Adaptation Strategy

The Biden administration has enormous climate and carbon management goals, which rightfully include the geologic sequestration of carbon dioxide as a core part of its climate adaptation strategy. The administration, to its...more

Biden WOTUS Final Rule at OMB

On September 12, with exactly three weeks until the U.S. Supreme Court hears oral argument in the Sackett v. EPA case, EPA sent the latest iteration of a final rule to define “Waters of the U.S.” (WOTUS) to the Office of...more

First Major CERCLA Move for PFAS

Today, the U.S. Environmental Protection Agency (EPA) announced that Administrator Regan signed a proposed rule to designate two of the most widely studied per- and polyfluoroalkyl substances (PFAS) as hazardous substances...more

EPA Proposes Federal Water Quality Standards for Washington State

In a move consistent with EPA’s recent uptick in oversight of state regulatory programs, EPA has proposed to establish federal water quality standards (WQS) for human health criteria (HHC) for Washington state. The proposal...more

Innovation in Iowa: Talking About the Future of Watershed Management With Iowa Agriculture Secretary Mike Naig - Reflections on... [Audio]

Developments in water law and policy are highly relevant to our way of life. Drawing from their wealth of experience as defense attorneys, prosecutors, policy makers, and most recently having run the Office of Water at the...more

Draft 401 Certification Rule Proposal Sent to OMB

On March 25, EPA sent a proposed Clean Water Act Section 401 Water Quality Certification rule to the Office of Management and Budget (OMB) for interagency review. Once cleared by OMB, the proposal will be published in the...more

EPA Budget Includes CCS Injection Program Investment

EPA’s budget, approved by Congress last week, increases investment in the agency’s Safe Drinking Water Act Underground Injection Control (UIC) program....more

EPA Issues Guidance for Use of Infrastructure Dollars

EPA’s Office of Water recently issued guidance on the Implementation of the Clean Water and Drinking Water State Revolving Loan Fund Provisions of the Bipartisan Infrastructure Law. The memorandum itself is eight pages long...more

Diving In: An Interview With Radhika Fox, Assistant Administrator, Office of Water - Reflections on Water Podcast [Audio]

Dave Ross talks with Radhika Fox as she marks her one year anniversary as EPA’s Assistant Administrator for Water. They discuss how her prior experiences prepared her for the role at EPA and her desire to change the narrative...more

EPA Moves to Elevate Tribal Rights in Water Quality: Changes Could Modify CWA Implementation

The Environmental Protection Agency (EPA) has initiated two rulemaking actions, both expected to be proposed in early 2022, that could change the way the Clean Water Act (CWA) is administered across the country. ...more

EPA and Army Corp’s Joint Section 401 Guidance Walks Back Regulatory Certainty

On August 19, EPA and the Army Corps of Engineers (Corps) issued a joint guidance document concerning implementation of EPA’s 2020 Water Quality Certification Rule. The agencies explain that the guidance applies specifically...more

EPA Finalizes Recommended Nutrient Criteria for Lakes and Reservoirs

On August 13, EPA finalized Clean Water Act (Act) Section 304(a) recommended criteria for phosphorus and nitrogen in lakes and reservoirs. The new recommendations incorporate scientific models that states and tribes with...more

EPA Signals More Stringent Regulation for Steam Electric Power Generators

EPA announced yesterday its intent to revise some portions of the 2020 Steam Electric Effluent Limitation Guideline Reconsideration Rule (2020 ELG Rule). EPA’s press release and the pre-publication version of its Federal...more

EPA Announces Reconsideration and Potential Revision of the Clean Water Act Section 401 Final Rule

On May 27, the Environmental Protection Agency (EPA) announced its intent to reconsider the Clean Water Act (CWA) Section 401 final rule issued by the Trump administration in June 2020 (Final Rule)....more

Second Circuit Enforces the Clean Water Act Section 401 One-Year Time Limit

On March 23, the Second Circuit issued its opinion in N.Y. Dep’t of Enviro. Conservation v. FERC, Case No. 19-1610 (i.e., the “Empire Pipeline” case). The case concerns the Federal Energy Regulatory Commission’s (FERC or...more

EPA Publishes Advance Notice of Proposed Rulemaking in Preparation for Crafting PFAS Effluent Limitations Guidelines

On March 17, the U.S. Environmental Protection Agency (EPA) published an Advance Notice of Proposed Rulemaking (ANPRM) that puts forth 28 questions directed at manufacturers and formulators of per- and polyfluoroalkyl...more

Businesses Grappling with Federal Regulation May Look to States as Allies

As the Biden administration settles in, the pendulum of federal power has begun to swing back toward greater regulation. In response, regulated entities are beginning to review their range of options to engage in, challenge,...more

Don’t Forget the States as You Grapple with Federal Regulation

As the Biden administration settles in, the pendulum of federal power has begun to swing back toward greater regulation. Regulated entities will want to review their range of options to engage in, challenge, or prepare for...more

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