News & Analysis as of

Clean Air Act Affirmative Defenses Final Rules

Snell & Wilmer

Title V Emergency Affirmative Defense Provision Reinstated by DC Circuit Court

Snell & Wilmer on

The DC Circuit Court of Appeals decided on September 5, 2025, that the U.S. Environmental Protection Agency (EPA) erred in implementing its 2023 Final Rule on “Removal of Title V Emergency Affirmative Defense Provisions From...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Removal of Title V Emergency Affirmative Defense Provisions/State Operating Permit Programs: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a final rule in the July 21st Federal Register that removes the emergency affirmative defense provisions found in the regulations for state and federal Title V...more

Williams Mullen

Environmental Notes - August 2016

Williams Mullen on

Time to Pay More: EPA Increases Maximum Civil Penalties - Remember the days when the maximum civil penalty EPA could assess for a violation of environmental law was $25,000 per day? Those days disappeared 26 years ago...more

Williams Mullen

EPA Issues SIP Call to Eliminate SSM Defense

Williams Mullen on

EPA has issued a final rule that requires 36 states to revise their State Implementation Plans to eliminate a well-known and often-used Clean Air Act defense for excess emissions. While specific elements of the defense...more

Blank Rome LLP

EPA Requires States to Revise and Tighten Startup, Shutdown, and Malfunction Regulations

Blank Rome LLP on

Action Item: In response to pressure from environmental groups, EPA has removed Clean Air Act affirmative defenses previously available to the regulated community for startups, shutdowns, or malfunctions (SSM Rule). The...more

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