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Clean Water Act: The End of “End-Result” Permitting

The Supreme Court of the United States’ recent Clean Water Act decision in City of San Francisco v. EPA has sent shockwaves through the environmental community by prohibiting EPA and state agencies’ common practice of...more

Environmental Notes - April 2025

Under the Clean Air Act, sources frequently must undergo “New Source Review” (NSR) permitting, which is a pre-construction permitting program. NSR establishes requirements for new or modified sources prior to initiating...more

EPA Proposes Changes to Methods for Analyzing Water Pollutants, including PFAS and PCBs

EPA is proposing to promulgate new methods and update the regulatory tables of approved methods for pollutant analysis under the Clean Water Act specified in 40 CFR Part 136. The proposed rule affects the methods used to...more

Environmental Notes - January 2025

EPA late last year finalized rules banning use of trichloroethylene (TCE) in the United States and certain consumer uses of perchloroethylene (PCE) under the Toxic Substances Control Act (TSCA). Both chlorinated chemical...more

Dust Off Your Rulebook: EPA’s New Dust-Lead Standards

EPA has published a Final Rule which will lower dust-lead standards in pre-1978 homes and childcare facilities. Under TSCA Section 403, EPA must identify and regulate lead-based paint hazards....more

Chevron Overruled - The Widespread Impact Might Just Surprise You

The Supreme Court overruled the 40-year-old Chevron doctrine of judicial deference given to administrative agency actions in an opinion released last week. On June 28, 2024, the court held that federal courts no longer must...more

Communication is Key: OSHA’s Amended Hazard Communication Standard

OSHA is amending its Hazard Communication Standard (HCS) regulations which require chemical manufacturers and importers to classify the hazards of chemicals they produce or import and to provide their employees information...more

What to Know About EPA’s Inflation Adjustments for Civil Penalties

EPA recently promulgated a final rule (the Rule) adjusting civil penalties issued by the agency for inflation. This action was performed pursuant to the Federal Civil Penalties Inflation Adjustment Act of 1990, as amended by...more

Environmental Notes - February 2024

Clock is Ticking as EPA Proposes Ban of the Manufacture, Processing and Commercial Use of the Widely Used Chemical TCE - EPA recently proposed a ban of trichloroethylene, commonly known as TCE, under the Toxic Substances...more

Proposed Rule: Avoiding a Worst-Case Scenario for Worst-Case Discharges

EPA is poised to issue a final rule (the Rule) requiring stringent planning requirements for facilities with the potential for a “worst-case discharge” that could reasonably be expected to cause substantial harm to the...more

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