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Déjà vu? FWS Solicits Feedback to Update Section 10(a) of the ESA

On Monday, June 9, the U.S. Fish and Wildlife Service (FWS) opened a short, 30-day public comment period soliciting information and comments to, “improve the overall efficiency and effectiveness” of Section 10(a) take...more

One-Track Mind: Unanimous SCOTUS Decision on Rail Line Approval Further Narrows Scope of NEPA

On May 29, the Supreme Court issued a unanimous opinion in Seven County Infrastructure Coalition v. Eagle County, Colorado that dramatically changes the way courts scrutinize federal agencies’ environmental reviews under the...more

No Harm, No Foul? Services Propose to Remove Harm Definition from Endangered Species Act Regulations

On April 17, the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) (together Services) published a proposed rule to rescind the long-standing definition of “harm” under the Endangered Species...more

Twin Killings: Executive Orders Put Existing Energy Regulations in the Crosshairs

On the evening of April 9, 2025, the Trump administration released a pair of deregulatory executive actions that could have major implications for any industry subject to federal rules — and are also likely to be a magnet for...more

Secretary of the Interior Burgum Fuels A Surge of Day One Energy Orders

Newly confirmed Interior Secretary Doug Burgum wasted little time implementing many of President Trump’s initial energy executive orders (EOs), unleashing a round of Secretary’s Orders (SOs) this past Monday that push fossil...more

First Day Presidential Directives May Have Broad Implications for Wind Industry

Among President Donald Trump’s directives issued on his first day in office was a Presidential Memorandum targeting wind energy, which has been a significant source of new electricity generation in the United States over the...more

Final ESA Rules Include Fundamental Shift in RPMs

On March 27, the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) (collectively, the Services) issued three sets of final rules revising the Endangered Species Act (ESA) regulations. The...more

FWS Prepares for Tricolored Bat Listing With New Guidance

The U.S. Fish and Wildlife Service (FWS) continues to focus on protections for bat species that have been ravaged by white-nose syndrome. In 2023, the Northern Long-Eared Bat (NLEB) was uplisted to endangered status. The FWS...more

Changes to Eagle Take Permitting Finalized by Fish and Wildlife Service

Effective April 12, a new eagle take permitting regime will be in place. The eagle take permitting scheme has been criticized because of its overly conservative and burdensome requirements. These concerns culminated in a...more

Louisiana v. EPA: A Turning Point for Title VI and Environmental Justice?

At the end of January, a federal judge issued a ruling in a high-profile environmental justice case, Louisiana v. EPA, brought by Louisiana against the Environmental Protection Agency (EPA) and the U.S. Department of Justice...more

Air and Climate Report: January 2024

PM NAAQS: Already behind schedule is perhaps the mostly widely impactful rule change EPA has proposed in many years: a lowering of the national ambient air quality standard (NAAQS) for fine particulate matter (PM2.5). EPA has...more

Fish and Wildlife Service Revises Its Mitigation Policies

Last week, the U.S. Fish and Wildlife Service (FWS) released two revised compensatory policies. The Mitigation Policy and the ESA Compensatory Mitigation Policy reject the stringent goal of net conservation gain used by the...more

New Jersey Moves Forward with Implementation of First-of-Its-Kind Environmental Justice Statute

In 2020, New Jersey enacted a first-of-its-kind environmental justice statute, the Environmental Justice Law (EJ Law). The EJ Law requires that permit applicants for certain water, waste, and air facilities located, wholly or...more

President Biden Signs Executive Order on Environmental Justice

On April 21, President Biden signed Executive Order No. 14096 (EO), titled “Revitalizing Our Nation’s Commitment to Environmental Justice For All.” The EO builds on prior executive orders by President Biden related to...more

Fish and Wildlife Service Proposes to List Tricolored Bat as Endangered

On September 14, the U.S. Fish and Wildlife Service (FWS) issued a proposal to list the tricolored bat (Perimyotis subflavus) as an endangered species....more

Environmental Groups Target Texas Air Permitting Program on Environmental Justice Grounds

On June 28, a coalition of 11 environmental groups petitioned the U.S. Environmental Protection Agency (EPA) under the Administrative Procedure Act and the Clean Air Act to address the alleged failure of Texas Commission for...more

Trump ESA Rules Vacated

The Endangered Species Act (ESA) regulations promulgated by the Trump administration (Trump ESA Rules) were challenged by environmental groups. While that challenge was pending, the Biden administration announced that those...more

Changes to Migratory Bird Treaty Act Program Announced

On October 4, the U.S. Fish and Wildlife Service (FWS) published a revision of its interpretation of the Migratory Bird Treaty Act (MBTA). With the final rule, FWS has effectively reinstated its position that “incidental...more

Notice of Proposed Rulemaking for NEPA Revisions Announced

On October 7, the Council on Environmental Quality (CEQ) issued a Notice of Proposed Rulemaking (NOPR) to revise its regulations implementing the National Environmental Policy Act (NEPA), which requires federal agencies to...more

State Laws Provide New Pathways for Environmental Justice Claims

Environmental justice moved to the forefront of sociopolitical discussions in the country in 2020, receiving increased attention from politicians, community groups, and environmental agencies. Although this concept is not...more

Washington Adopts Two Ambitious Environmental Justice Laws

Last week, Washington became the latest state to address environmental justice (EJ) through legislation by adopting the Healthy Environment for All (HEAL) Act and the Climate Commitment Act into law. The HEAL Act, which is...more

Preparing for a More Aggressive Federal Environmental Enforcement Regime

The Biden administration has already taken several actions that signal its intention to shift to a more federally focused environmental enforcement approach. Although the Trump administration generally adopted a “hands off”...more

Gas Pipeline Regulatory Reform Rule Finalized

On January 11, the Pipeline and Hazardous Materials Safety Administration (PHMSA) finalized its June 2020 proposed rulemaking intended to reduce regulatory burdens and offer greater flexibility to gas pipeline operators,...more

1/14/2021  /  Energy Sector , Oil & Gas , PHMSA , Pipelines

FWS Finalizes Rule for Excluding Areas from Critical Habitat Designations

The U.S. Fish and Wildlife Service (FWS) continues its push to finalize pending rules before the new administration takes office next year. Following a publication of a final rule defining “habitat” under the Endangered...more

Final Rule Defining “Habitat” under the Endangered Species Act Issued

In a case involving the question of when unoccupied habitat may be designated “critical habitat” under the Endangered Species Act (ESA), the U.S. Supreme Court held that critical habitat land must first be habitat before it...more

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