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Active Battle Over the California Clean Air Act Waiver Continues

California's ability to set its own vehicle emission standards under its Clean Air Act waiver of federal preemption is in jeopardy given three joint congressional resolutions signed into law by President Trump on June 12,...more

U.S. Supreme Court Limits EPA Clean Water Act Permitting Authority

On March 4, 2025, the Supreme Court of the United States issued its decision in City & County of San Francisco v. Environmental Protection Agency and clarified the U.S. Environmental Protection Agency's ("EPA") and state...more

D.C. Circuit Court of Appeals Rejects Challenge to California's Limits on Automotive Greenhouse Gas Emissions

In Ohio et al. v. U.S. EPA, on April 9, 2024, the United States Court of Appeals for the D.C. Circuit upheld a decision by the U.S. Environmental Protection Agency ("EPA") to allow California's 2013 greenhouse gas emissions...more

EPA Finalizes Rules to Regulate Pollution from Fossil Fuel-Fired Power Plants

On April 25, 2024, the Environmental Protection Agency ("EPA") finalized four rules to regulate pollution from fossil fuel-fired power plants. EPA's stated goal was to provide a framework on which power plants can rely for...more

EPA Designates PFOA and PFOS as CERCLA Hazardous Substances

On April 19, 2024, EPA announced its highly anticipated final rule designating two polyfluoroalkyl substances ("PFAS")—perfluorooctanoic acid ("PFOA") and perfluorooctanesulfonic acid ("PFOS")—as "hazardous substances" under...more

EPA Finalizes New Emission Standards for Heavy-Duty Vehicles

The U.S. Environmental Protection Agency ("EPA") finalized the strictest-ever emission standards for heavy-duty vehicles. On March 29, 2024, EPA announced new emission standards for heavy-duty vehicles for model years 2027...more

EPA Announces New Stringent Emissions Standards for the Auto Industry

The U.S. Environmental Protection Agency ("EPA") announced new stringent emissions standards for automobiles, which the Biden administration has deemed the "strongest-ever vehicle pollution standards" in U.S. history....more

EPA's PFAS Reporting Rule Requires Broad Retroactive Disclosure of PFAS Data

The Situation: In 2019, Congress amended the Toxic Substances Control Act ("TSCA") to require the Environmental Protection Agency ("EPA") to promulgate a reporting rule on per- and polyfluoroalkyl substances ("PFAS"). EPA...more

U.S. Intensifies Environmental Crime Enforcement in Puerto Rico and U.S. Virgin Islands

In Short - The Situation: The U.S. Department of Justice ("DOJ" or "Department") and the U.S. Environmental Protection Agency ("EPA") recently announced the creation of a regional, cross-agency taskforce, targeting...more

Supreme Court Issues Wetlands Ruling in Sackett v. EPA Decision

In Short - The Development: On May 25, 2023, the United States Supreme Court issued its decision inSackett v. EPA, providing new insight into whether wetlands qualify as "waters of the United States" subject to regulation...more

EPA Proposes New Carbon Pollution Standards for Fossil Fuel-Fired Power Plants

The Environmental Protection Agency ("EPA") is proposing stringent carbon dioxide emissions standards for coal- and gas-fired power plants....more

EPA is Seeking Comment on Potential Designations of Additional PFAS as Hazardous Substances Under CERCLA

The Advance Notice of Proposed Rulemaking ("ANPRM") addresses seven per- and polyfluoroalkyl substances ("PFAS"), including PFBS and GenX. ...more

EPA Proposes Stricter Mercury and Air Toxics Standards for Power Plants

The Environmental Protection Agency ("EPA") has announced a new proposed rule that would strengthen the National Emission Standards for Hazardous Air Pollutants ("NESHAP") for Coal- and Oil- Fired Electric Utility Steam...more

EPA Proposes Standards to Limit Certain PFAS Substances in Drinking Water

On March 14, 2023, the EPA took a step toward imposing federal limits on certain per- and polyfluoroalkyl substances in drinking water under the Safe Drinking Water Act. The United States Environmental Protection Agency...more

EPA and Army Corps Promulgate New Expansive Definition of Waters of the United States

In Short - The Situation: In 2021, the Biden Administration signaled its intent to replace the 2020 "Navigable Waters Protection Rule," which was vacated by a federal court, with a new definition of "waters of the United...more

EPA Issues Guidance Addressing Discharges of PFAS

In Short - The Situation: The Environmental Protection Agency's ("EPA") new guidance memorandum to states provides direction on how they can use the National Pollutant Discharge Elimination System ("NPDES") permitting...more

EPA Proposes Designating PFOA and PFOS as Hazardous Substances Under CERCLA

The EPA announced on August 26, 2022, a proposed rulemaking that would designate perfluorooctanoic acid ("PFOA") and perfluorooctanesulfonic acid ("PFOS"), including their salts and structural isomers, as hazardous substances...more

The Climate Report | First Quarter 2022

The delegated regulation includes a new comprehensive and unified reporting methodology to direct investments toward environmentally sustainable economic activities....more

EPA Issues Stringent Greenhouse Gas Emissions Standards for Passenger Cars and Light Trucks

On December 30, 2021, the U.S. Environmental Protection Agency ("EPA") published a final rule (the "Final Rule") setting revised greenhouse gas emissions standards for passenger cars and light-duty trucks with model years...more

Regulators in the United States and Europe Move to Restrict PFAS in Products and Wastes

The Background: In recent years, the scientific and regulatory communities have paid increasing attention to per- and polyfluoroalkyl substances ("PFAS"), which have been common components for decades in consumer and...more

California Governor Issues Executive Order Requiring Transition to 100% Zero-Emission Vehicle Sales

On September 23, 2020, California Governor Gavin Newsom issued Executive Order N-79-20 (the "Order"), setting new statewide goals for phasing out gasoline-powered cars and trucks in California. Under the Order, 100% of...more

Challenges to Safer Affordable Fuel-Efficient Vehicles Rule Keep Coming

On June 26 and 29, 2020, the petitioners in Union of Concerned Scientists v. NHTSA, Case No. 19-1230 (D.C. Cir.), filed briefs with the U.S. Court of Appeals for the District of Columbia Circuit, arguing against the first...more

The Climate Report | Second Quarter 2020

Climate Change Regulatory Issues & Updates - NHTSA and EPA Finalize the Safer Affordable Fuel-Efficient Vehicles Rule - The new rule completes the rollback of the Obama-era vehicle emissions standards....more

Supreme Court Rules Some Discharges to Groundwater Require Clean Water Act Permits

The Situation: The Supreme Court held that a discharge through groundwater that is the functional equivalent of a direct discharge to navigable waters requires a Clean Water Act permit. The Result: Some discharges to...more

U.S. Supreme Court Permits State Law Claims for Restoration Damages at Superfund Sites

The Situation: The U.S. Supreme Court recently considered, in Atlantic Richfield Co. v. Christian, whether the Comprehensive Environmental Response, Compensation and Recovery Act ("CERCLA") deprives Montana state courts of...more

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