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Massachusetts Supreme Judicial Court Upholds GHG Caps for Electricity Sector and Affirms the Continued Viability of Chevron-style...

On September 4, 2018, the Massachusetts Supreme Judicial Court (SJC) issued an opinion in New England Power Generators Association v. Department of Environmental Protection (Case number SJC-12477; --- N.E.3d ---, 2018 WL...more

EPA Proposes to Rescind RMP Provisions Amended Under Obama Administration, Seeks Comments

On May 30, 2018, the U.S. Environmental Protection Agency (EPA) published a proposed rule (Proposed Rule) that would rescind the majority of the amendments to the RMP rule that were finalized in January 2017 in the final days...more

Environmental Enforcement Policy Developments: The Trump Administration and Congress Make Their Mark

During the past year, numerous developments have signaled a change in approach to environmental enforcement as it is being conducted by the Trump Administration. Enforcement continues, in several cases on high profile...more

MassDEP Issues Air Rule Amendments

Culminating a two-year rule promulgation process, MassDEP has issued a final rule amendment package that makes adjustments to numerous provisions of the Massachusetts air regulations. The announced purpose of this package...more

Massachusetts Land Court Applies New Article 97 Guidance and Denies Constitutional Protection to Land Purchased for Water Resource...

We recently reported on a new analytical framework created by the Massachusetts Supreme Judicial Court in the case of Smith v. City of Westfield for conducting analyses to determine whether Article 97 state constitutional...more

12/21/2017  /  Conservation , Water , Water Conservation

Playground Permanently Dedicated and Used As a Public Park Earns Massachusetts Constitutional Protections of Article 97

The Massachusetts Supreme Judicial Court has reinterpreted the test for determining whether municipal parklands are protected by article 97 of the Amendments to the Massachusetts Constitution. This decision means that more...more

EPA Region 1 Increasingly Targeting Ammonia Refrigeration Processes for RMP and General Duty Clause Enforcement

Over the course of 2017, U.S. EPA Region 1 has settled several significant enforcement matters arising under the risk management provisions of the Clean Air Act, Section 112(r). The risk management requirements are intended...more

EPA Delays Effective Date of RMP Rule Amendments, Environmental Groups File Challenge

On June 14, 2017, EPA published a final rule in the Federal Register delaying the effective date of its Risk Management Program (RMP) rule amendment package for twenty months, until February 19, 2019. EPA’s decision was...more

D.C. Circuit Signals Limits on EPA’s Authority to Reduce Requirements in Existing Environmental Rules: Waterkeeper Alliance v. US...

As the Trump Administration seeks to re-write many of the nation’s environmental rules, the U.S. Court of Appeals, District of Columbia Circuit, has issued a decision in Waterkeeper Alliance v. US EPA that signals the...more

OMB Signs Off on U.S. EPA’s 2017 Construction Stormwater Permit

Spared by the Office of Management and Budget from the Trump Administration’s regulatory freeze, the U.S. Environmental Protection Agency’s (EPA) 2017 National Pollutant Discharge Elimination System General Permit for...more

Landfill Expansion Project Halted by MassDEP

Company Settles MassDEP enforcement case, Reaches Agreement with MassDEP to split $10 Million Cost to Construct Drinking Water Line and Receives Notice of Intent to Sue from Environmental Groups - A proposal to expand...more

EPA Stays RMP Rule Amendments and Grants Petition for Reconsideration

The U.S. Environmental Protection Agency has stayed the implementation of a significant revision of the Risk Management Program (RMP) rule pending the receipt of additional comments. Simultaneously, EPA has granted a request...more

Massachusetts Proposes New Greenhouse Gas Rules for Electric Generation, Natural Gas, and Transportation Sectors

On December 16, 2016, the Massachusetts Department of Environmental Protection (“MassDEP”) released draft rules that would impose new greenhouse gas (“GHG”) requirements on the electric energy sector, gas distribution...more

Massachusetts Environmental and Land Use Alert

Off to Court We Go: Petitioners Challenge EPA’s Small MS4 General Permit for Massachusetts - The storm of debate and criticism over the terms and conditions of the U.S. Environmental Protection Agency’s (EPA) General...more

“Oh The Times . . . They are A-Changing:” EPA & DOJ Follow Through on Worker Endangerment Initiative

On October 12, 2016, the U.S. Department of Justice (“DOJ”) announced that four Texas companies agreed to plead guilty to criminal violations of the Clean Air Act at oil and chemical processing facilities, and to collectively...more

Stormwater Forecast: Prepare for More Aggressive Benchmark Monitoring and Corrective Action Requirements under the Next Proposed...

EPA is expected to propose a revised system of benchmark monitoring and corrective action requirements to replace those of the current 2015 Multi-Sector General Permit for Stormwater Associated with Industrial Activities...more

Supreme Judicial Court Orders the Massachusetts Department of Environmental Protection to Expand Greenhouse Gas Regulation

More greenhouse gas regulation is on the horizon as a result of the Massachusetts’ top court’s decision in Kain v. MassDEP. The Massachusetts Supreme Judicial Court ordered the Massachusetts Department of Environmental...more

Does Your Toxic Release Inventory Make You a Target for Enforcement?

Summary: The U.S. Environmental Protection Agency’s Office of the Inspector General is examining the Agency’s usage of Toxic Release Inventory data to evaluate companies’ compliance with surface water discharge permitting...more

New Conservation Restrictions for the Northern Long-Eared Bat Will Have Limited Impact on Development in Massachusetts

A new Endangered Species Act rule protecting the northern long-eared bat will likely have only limited impact on development and land use activities in Massachusetts due to fairly specific restrictions imposed by the final...more

EPA Issues Proposal to Amend RMP Rule

The U.S. Environmental Protection Agency (EPA) has released a long awaited proposal to update the Accidental Release Prevention rules at 40 C.F.R. Part 68, which implement the Clean Air Act Section 112(r)(7) risk management...more

EPA Proposes Numerous Changes to Greenhouse Gas Reporting Rule

On December 21, 2015, the EPA Administrator signed off on a fairly lengthy package of proposed changes to the GHG Reporting Rule, 40 CFR Part 98, and the proposal will be published soon in the Federal Register. There will be...more

First Circuit Court of Appeals Clarifies Limited Deference to Surface Transportation Board Views on Railroad Preemption

In two companion decisions released in October, 2015, the U.S. Court of Appeals, First Circuit, considered the extent to which federal preemption of state and local laws applies to railroad operations involving the...more

Massachusetts Supreme Judicial Court to Hear Appeal of Challenge to MassDEP’s Implementation of Global Warming Solutions Act

In April of 2015, we reported on an interesting Massachusetts Superior Court decision, Kain v. MassDEP, upholding the actions to date of the Massachusetts Department of Environmental Protection (“MassDEP”) under the Global...more

EPA Publishes Clean Power Plan And Initiates Concerted Attempt to Reduce GHG Emissions from Fossil Fuel Fired Power Plants

The Clean Power Plan is one of the most intensely scrutinized and debated rules in EPA’s history. The proposed rule, published in June of 2014, generated 4.3 million individual comments. The final rule was immediately...more

Massachusetts Department of Environmental Protection to Hold Listening Sessions under Executive Order 562

In April, we reported on Governor Baker’s issuance of Executive Order 562, a very broad Order that prohibits any Massachusetts agency from issuing new regulations for one year, unless certain conditions are met. In order to...more

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