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Developments in Class VI Delegation: Arizona and Texas Await Final Rules

On August 1, EPA’s comment period on its proposal to grant Texas “primacy” over permitting and enforcement of Class VI underground injection wells closed, marking another milestone in the expansion of state-managed Carbon...more

Environmental, Social & Governance (ESG)

Pressures from investors and other stakeholders, the wide range of ESG interests and issues, and the fluid nature of ESG can be overwhelming. The proposed rule serves as a reminder that companies should not overlook...more

EPA's Reconsideration of Ethylene Oxide Under the Clean Air Act - A Sign of Future Chemicals Policy to Come?

On January 25, 2022, the U.S. Environmental Protection Agency (“EPA”) reaffirmed its interpretation of ethylene oxide (“EtO”) requirements which may signal EPA’s increased scrutiny of chemical emissions generally and the...more

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