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Particulate Matter Has Not Clouded My Crystal Ball

Last month, I noted that EPA’s Office of Air Quality Planning and Standards had released a draft reassessment of the particulate matter NAAQS. In a bold moment of speculation, I indicated that it would be difficult for EPA to...more

Boston's Climate Action Plan Update: The Time Has Come For Buildings!

Last week, Boston released its Climate Action Plan 2019 Update. The Update identifies “priority actions” for the next five years necessary to put Boston on a trajectory towards carbon neutrality by 2050. There’s a lot in the...more

The Other Shoe Drops on Upwind Ozone States

On Tuesday, the District of Columbia Court of Appeals vacated EPA’s “Close-Out Rule,” which basically concluded that upwind states contributing to exceedances of the National Ambient Air Quality Standard for ozone in downwind...more

Injunctive Relief Is Available Outside the Fenceline

On Monday, District Judge Rodney Sippel ordered sweeping injunctive relief against Ameren Missouri, intended to remedy violations of PSD requirements he had previously identified resulting from upgrades to the Ameren Missouri...more

The Trump Administration Couldn't Spell Irony If You Spotted It the I, R, O, and N.

Yesterday, EPA and the National Highway Traffic Safety Administration released the “Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule Part One: One National Program,” more succinctly known as the withdrawal of the...more

Good Neighbors Delayed Are Good Neighbors Denied

Last Friday, the D.C. Circuit Court of Appeals ruled that EPA violated the Clean Air Act in failing to impose deadlines on upwind states violating the CAA’s Good Neighbor provisions. The Court concluded that, where downwind...more

Environmental Protection Is an Afterthought at the Environmental Protection Agency

Last week, EPA and the Army Corps of Engineers promulgated the final rule repealing the 2015 rule defining the Waters of the United States. The repeal rule is 172 pages in its pre-publication version. The word “science” is...more

Hope Springs Eternal at the Climate Leadership Council

The Carbon Leadership Council, everyone’s favorite group of former grand poohbahs, is still working at building support for its “carbon dividends” plan. Hope springs eternal. And I don’t mean to make light of the CLC’s...more

Particulate Matter Is More Dangerous Than We Thought: What Will EPA Do With the NAAQS?

EPA’s Office of Air Quality Planning and Standards has released a draft of its reassessment of the adequacy of the current national ambient air quality standard for particulate matter. Here’s the primary takeaway concerning...more

Heads Trump Wins; Tails Regulation Loses

Earlier this week, the Department of Energy withdrew definitions of “general service lamps” and “general service incandescent lamps” promulgated under the Obama administration. The effect is it eliminate requirements that...more

EPA Proposes to Eliminate Oil and Gas Methane Rules: Just Another Brick in the Deregulatory Wall

Last week, EPA proposed to eliminate regulation of methane emissions from the oil and gas industry. The most noteworthy response to the proposal came from the large producers. ExxonMobil, Shell, and BP all oppose the...more

EPA's Ozone NAAQS Largely Survives: CASAC Still Rules

The D.C. Circuit today largely upheld EPA’s 2015 revisions to the National Ambient Air Quality Standard for ozone. I’m not much of a prognosticator, but I pretty much called this one years ago. The Court was never going to...more

If It Walks Like a Duck and Talks Like a Duck, It May Still Not Be Sauce for the Gander

Earlier this week, the D.C. Circuit Court of Appeals held that the “Wehrum Memo,” which reversed EPA’s longstanding policy of “once in, always in” regarding MACT jurisdiction, was not final agency action subject to judicial...more

TMDL — It Means Total Maximum Daily Load. Literally.

Earlier this week, Judge Christopher Cooper of the District Court for the District of the Columbia, struck down EPA’s approval of Total Maximum Daily Loads established by the District of Columbia for the Anacostia and Potomac...more

Changes to ESA Regulations: How Significant Are They?

The Fish and Wildlife Service and the National Oceanic and Atmospheric Administration have released final rules amending significant parts of the regulations implementing the Endangered Species Act. How big an impact will...more

More Sauce For the Chevron Goose

Last week, EPA proposed revisions to its regulations governing the issuance of water quality certifications under § 401 of the Clean Water Act. The regulations are long-overdue and, notwithstanding the source, some of the...more

Climate Change Litigation Strategy: Swing For the Fences or Hit Singles?

Those seeking to address climate change through litigation have taken two different paths. Some cases, probably best represented by Juliana v. United States, have plaintiffs who are swinging for the fences. These are...more

The Trump Administration Provides Another Lesson in How to Lose An Environmental Case

Last week, the 4th Circuit Court of Appeals vacated the Fish and Wildlife Service’s Biological Opinion and Incidental Take Statement for the Atlantic Coast Pipeline. It’s the second time that the Court has rejected the FWS...more

Some Say the World Will End in Fire; Some Say in Floods

I’ve always understood that heat causes more fatalities than other weather-related phenomena. It’s only going to get worse with climate change. If you thought that climate change was all about rising sea levels, think again....more

Mitigating GHG Emissions From Buildings. The Drumbeat Is Getting Louder

I’ve posted a number of times about the coming wave of efforts to reduce or eliminate GHG emissions from buildings. Notwithstanding Washington’s current intransigence, the electric sector is now decarbonizing. With that...more

Is Putin's Deep Game to Make Money From Climate Change?

ClimateWire (subscription required) reported yesterday that Russia plans to join the Paris Agreement. Apparently, Russia is doing so because it sees a global move to a low-carbon economy and it doesn’t want to be left behind....more

Last of An Endangered Species Spotted on Capitol Hill: A Practical Senator

Bloomberg Environment (subscription required) is reporting this morning that Senator Chris Coons is trying to persuade Democrats that they should agree to limit EPA’s authority to regulate greenhouse gases in return for GOP...more

Affordable Clean Energy — Or, Much Ado About Nothing

Here’s my take on the Affordable Clean Energy Plan. Who cares? On the merits, it does almost nothing. It requires only that states impose heat rate improvement requirements on coal-fired power plants. It’s not going to...more

Affordable Clean Energy or Carbon Free?

Yesterday, EPA finalized its Affordable Clean Energy rule, which will replace the Obama Clean Power Plan. More on ACE later. For now, I just want to use the ACE roll-out to contrast what’s happening at the federal level with...more

Asbestos. Lead Paint. MTBE. PFAS?

Late last month, New Hampshire filed two law suits seeking to recover a variety of costs and damages it alleges have resulted from contamination caused by releases of PFAS. It’s a wide ranging suit; New Hampshire asserted...more

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