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It’s the Energy Markets, Stupid (And Energy Markets Are Complex)

This week, the Massachusetts Attorney General’s office released a white paper documenting the results of a symposium convened last fall to discuss how electric markets should be organized to manage the transition to a “low /...more

Baltimore’s Climate Case Will Be Heard in State Court

Last week, the 4th Circuit Court of Appeals affirmed the District Court decision remanding Baltimore’s climate change litigation to state court. I wouldn’t read too much into the decision, which is founded on the niceties of...more

Federalism and the Regulation of PFAS

There has been much angst at the state level that EPA has not moved faster to develop drinking water or cleanup standards for PFAS. One of the states affected by the pace of EPA’s regulatory efforts is New Hampshire. Taking...more

The Science Advisory Board Lives!

The attack on science by this administration is not news at this point. Part of that attack has been to increase the number of industry scientists on EPA’s Science Advisory Board. I have no objection per se to additional...more

Trees Don’t Have Standing and Lake Erie Does Not Have a Bill of Rights

Almost 50 years ago, Christopher Stone published “Should Trees Have Standing,” suggesting that the natural world should be given legal rights to ensure its protection for future generations. It is not, I say with my usual...more

3/2/2020  /  Municipalities , Standing

Can Market-based Approaches Help to Clean Up the Great Lakes? Why the Heck Not?

Earlier this week, EPA announced grants for the development of market-based programs to address water quality problems in the Great Lakes, as part of the Great Lakes Restoration Initiative. I’ve spent more than a little time...more

Evidence That Low Exposures to Particulate Matter Pose Health Risks Continues to Accumulate — Will Administrator Wheeler Listen?

EPA’s Office of Air Quality Planning and Standards has issued its final “Policy Assessment for the Review of the National Ambient Air Quality Standards for Particulate Matter.” The Policy Assessment comes with the standard...more

Being Endangered Is Not the Same as Being Threatened

Late last month, Judge Emmet Sullivan of the Federal District Court for the District of Columbia, remanded to the Fish and Wildlife Service its decision to list the northern long-eared bat as threatened. The decision is...more

The “Navigable Waters Protection Rule” — Candidate For Misnomer of the Year

Yesterday, EPA and the Army Corps of Engineers finalized their revisions to the definition of Waters of the United States. There’s nothing in here that everyone didn’t already know. The agencies largely sidestepped the...more

The Wehrum Memo Still Isn’t Final Agency Action

The D.C. Circuit Court of Appeals has denied the petition for rehearing in the “once in, always in” case. It was a one sentence order. Judge Rogers, who dissented from the original panel opinion, dissented from the denial....more

Being On the Eve of Destruction Does Not Provide a Basis for Judicial Relief

Last week, the 9th Circuit Court of Appeals ruled that the plaintiffs in Juliana v. United States do not have standing. Given where we are, this is about as momentous a decision as I can imagine. I get the majority opinion....more

President Trump’s NEPA Reform Is the Opposite of Nixon in China

Ever since President Nixon visited China, significantly contributing to a thawing of the Cold War, the phrase “Nixon in China” has referred to any situation where a leader makes a policy move that would have been more...more

The Science Advisory Board Agrees With Me!

At the end of the December, the EPA Science Advisory Board posted the text of a letter that the SAB intends to send to Administrator Wheeler concerning the administration’s proposed revision to the WOTUS rule. The SAB’s...more

Cooperative Federalism Still Requires Two To Tango

Earlier this month, the 9th Circuit Court of Appeals held that a long-term failure by a state to submit to EPA a TMDL for an impaired water can constitute a “constructive submission” of no TMDL, triggering an obligation on...more

A Carbon Fee on Transportation Fuels Is Not Coming Your Way Any Time Soon If You Live In New Hampshire

On December 17, 2019, I noted with enthusiasm the announcement that the states participating in the Transportation and Climate Initiative had released a new draft Memorandum of Understanding outlining the framework of what...more

Coming Your Way (Relatively) Soon: A Carbon Fee on Transportation Fuels

The 12 states and the District of Columbia participating in the Transportation and Climate Initiative announced yesterday the release of a new draft Memorandum of Understanding that outlines the framework of what they are...more

It’s Not Going to Be Easy to Be Green

The New York Citizens Budget Commission has released a report regarding the state’s ability to meet its ambitious GHG reduction targets. It’s sobering reading. The CBC states that it is “uncertain” whether New York can meet...more

EPA Revises Its Policy on “Ambient Air” — Is It Nefarious or Common Sense?

EPA Administrator Wheeler has distributed a “Revised Policy on Exclusions from ‘Ambient Air’”. Here’s the short version. EPA has long defined “ambient air” as outside air “to which the general public has access.”...more

More Evidence that Chevron Is Not a Liberal Plot

November 26, 2019, Judge William Young ruled that discharges to groundwater are not subject to Clean Water Act jurisdiction, even if they ultimately reach surface waters that are unambiguously waters of the United States. He...more

A Court Enjoins Implementation of NH DES PFAS Regulations — Almost!

Last week, Judge Richard McNamara ruled that the plaintiffs were likely to succeed in their challenge to the very stringent standards for PFAS in drinking water promulgated by the New Hampshire Department of Environmental...more

Is It a Sin to Cause Environmental Degradation? Will Calling It a Sin Be Helpful?

Last week, Pope Francis announced that the Catholic Church was considering introducing into the Catechism “the sin against ecology, the ecological sin against the common home.” My immediate question on seeing this...more

In Case You Missed It, We're in a Climate Emergency

Last week, BioScience published the “World Scientists’ Warning of a Climate Emergency.” It’s actually a nice piece of work – short, readable, to the point. In barely 4 pages, it concisely summarizes the fine mess we’ve gotten...more

Will The PM NAAQS Be the Real End of Agency Deference?

According to Bloomberg Environment (subscription required), EPA’s Clean Air Science Advisory Committee cannot reach agreement whether to recommend that the NAAQS for PM2.5 be lowered. Even after two years, I guess I had not...more

Sage Grouse Protections Restored; Another Hasty Regulatory Rollback Is Rolled Back.

Last week, Federal District Court Judge B. Lynn Winmill granted a preliminary injunction to various NGOs, barring the Bureau of Land Management from implementing amendments BLM had made in 2019 to protection plans for the...more

DOE Must Promulgate Energy Efficiency Standards Finalized By the Obama Administration

Last week, the 9th Circuit Court of Appeals affirmed a District Court ruling requiring the Department of Energy to publish in the Federal Register four rules finalized by the Obama administration, but not previously...more

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