On March 12, 2020, the Department of Justice (“DOJ”) Environment and Natural Resources Division (“ENRD”) issued a memorandum announcing a new policy precluding the use of a vast majority of Supplemental Environmental Projects...more
Smart companies are planning for scenarios under which they might not be able to comply with environmental laws because of COVID-19. The noncompliance might be trivial—failing to keep up certifications because recertification...more
3/30/2020
/ Coronavirus/COVID-19 ,
Critical Infrastructure Sectors ,
Enforcement Guidance ,
Environmental Liability ,
Environmental Policies ,
Environmental Protection Agency (EPA) ,
Manufacturers ,
Policy Statement ,
Relief Measures ,
Wastewater ,
Water Supplies
Guidance documents have always been important and useful tools for the regulated community to: glimpse how an agency might use its discretion, determine how an agency might apply a regulation, and simply understand complex...more
Last week, the EPA announced two significant settlements for violations of the Clean Air Act relating to emissions of volatile organic compounds (“VOCs”) from upstream oil and gas production facilities. These enforcement...more
1/30/2020
/ Air Pollution ,
Civil Monetary Penalty ,
Clean Air Act ,
Compliance ,
Consent Order ,
Department of Justice (DOJ) ,
Energy Storage ,
Environmental Protection Agency (EPA) ,
Environmental Violations ,
Injunctive Relief ,
NAAQS ,
National Emissions Standards ,
New Source Performance Standards (NSPS) ,
Oil & Gas ,
Popular ,
Recordkeeping Requirements ,
Reporting Requirements ,
Settlement Agreements ,
State Implementation Plans (SIPs) ,
Vapor Intrusion ,
Volatile Organic Compounds (VOC)