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EPA Rejects Clean Water Act “Conduit Theory”

Whether a discharge to groundwater that results in pollution of jurisdictional surface waters is regulated under the Clean Water Act (the “CWA”) is the subject of much debate, conflicting decisions from the Circuit Courts of...more

Energy Newsletter - March 2019

Texas Supreme Court Finds Anadarko is Entitled to Over $100 Million in Deepwater Horizon Defense Costs Based on Undefined Term in Insurance Policy - Insurance coverage litigation arising out of the 2010 Deepwater Horizon...more

Supreme Court and EPA to Address Broad Expansion of Clean Water Act Liability by Lower Courts

The scope of the Clean Water Act (“CWA”) has vexed the courts and lead agencies for over a decade. In one of the most significant environmental cases this year, on February 19, 2019, the Supreme Court granted the petition for...more

Energy Newsletter - January 2019

Clean Water Agencies Propose to Redefine and Limit “Waters of the United States” - The United States EPA and the United States Army Corps of Engineers are proposing to redefine—and significantly limit—the scope of “Waters...more

Clean Water Agencies Propose to Redefine and Limit “Waters of the United States”

The United States EPA and the United States Army Corps of Engineers are proposing to redefine—and significantly limit—the scope of “Waters of the United States” (“WOTUS”) that are subject to federal jurisdiction under the...more

Energy Newsletter - September 2018

A Texas Federal Judge Turns Up the Heat on Oil Companies Facing Climate Change-Related Securities Class Actions - On August 14, 2018, the United States District Court for the Northern District of Texas issued a...more

WOTUS Rule Now Applies in 26 States After Court Enjoins Suspension Rule

Injecting yet more confusion into the ongoing saga of the Waters of the United States (“WOTUS”) Rule, on August 16, 2018, the United States District Court for the District of South Carolina enjoined the WOTUS “Suspension...more

Trump Administration Solicits Comment on Proposed Endangered Species Act Reforms

On July 25, 2018, the United States Fish and Wildlife Service, the National Marine Fisheries Service, and the National Oceanic and Atmospheric Administration (the “Services”) published three proposed rules to reform...more

Clean Water Act Agencies Solicit Comments to Support Repeal of WOTUS Rule

On July 12, 2018, the United States Environmental Protection Agency (“USEPA”) and the United States Army Corps of Engineers (“USACE”) published a “Supplemental Notice of Proposed Rulemaking” soliciting additional comments on...more

Energy Newsletter - June 2018

Lessons for Sellers in Contracting with Emerging Market Buyers: The “Three R’s” to Structuring Payment Security Provisions - The recent rebound in the international energy industry is being driven, at least in part, by a...more

Energy Newsletter - May 2018

Courts Hold Clean Water Act Regulates Discharges through Groundwater, as Congress and Regulators Consider Responses - The Ninth Circuit and Fourth Circuit have joined a growing number of lower courts finding that the...more

Fish and Wildlife Service Issues Guidance Limiting Agency Authority Under Endangered Species and Migratory Bird Acts

The U.S. Fish and Wildlife Service (“FWS”) recently released two guidance documents that have the potential to streamline project development requirements related to endangered species and migratory birds: • First, FWS...more

Federal Agencies Agree to Streamline Environmental Review and Approval of Infrastructure Projects

Two years is the goal for completion of NEPA review - On April 9, 2018, the White House released a Memorandum of Understanding (“MOU”) between twelve federal agencies that is intended to increase the speed and reliability...more

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