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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

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

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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