On June 11, 2025, the U.S. Environmental Protection Agency ("EPA") announced a proposed rule to repeal key amendments to the 2024 Mercury and Air Toxics Standards ("MATS") for coal- and oil-fired electric utility steam...more
If finalized, the rule would eliminate both Obama- and Biden-era limits on GHG emissions from fossil fuel-fired power plants. On June 11, 2025, the US Environmental Protection Agency (EPA) released a proposed rule under...more
In a proposed rule published on June 24, 2024, EPA has proposed to remove eighteen affirmative defense provisions for malfunctions associated with violations of New Source Performance Standards (NSPS) and National Emission...more
The Waste-to-Energy Association (“WTEA”) submitted July 1st comments to the United States Environmental Protection Agency (“EPA”) addressing the proposed rule styled: Prevention of Significant Deterioration (PSD) and...more
The United States Environmental Protection Agency (“EPA”) issued a pre-publication version of a proposed rule that would remove affirmative defense provisions from certain Clean Air Act New Source Performance Standards...more
The U.S. Environmental Protection Agency ("EPA") has proposed regulations for calculating methane emissions fees required beginning this year under the Inflation Reduction Act ("IRA"). Section 136 of the Clean Air Act (added...more
The United States Environmental Protection Agency (“EPA”) published in the September 13th Federal Register a proposed rule that would amend the general provisions for Clean Air Act National Emission Standards for Hazardous...more
On July 21, 2023, the Environmental Protection Agency published a final rule eliminating an affirmative defense for Clean Air Act permit emissions violations caused by “emergency” circumstances. “Major sources” (i.e....more
On April 12, 2023, the Environmental Protection Agency (EPA) issued the notice of proposed rulemaking for “Multi-Pollutant Emission Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles” (the “proposed...more
After years of delays – largely due to the COVID-19 pandemic – on April 11, 2023, the U.S. Environmental Protection Agency finally issued two proposals that would reduce ethylene oxide (EtO) emissions affecting fence-line...more
EPA is proposing revisions to the new source review (“NSR”) permit program (“2022 Proposed Fugitive Emissions Rule”) under the federal Clean Air Act (“CAA”), which will codify the requirement that modifications account for...more
The United States Environmental Protection Agency (“EPA”) published a September 4th Federal Register Notice proposing the results of a Residual Risk and Technology Review (“RTR”) of the Clean Air Act National Emission...more
Last year, we reported on EPA’s decision to allow the expiration of a moratorium on the 2016 Obama Climate Action Plan rule and guidelines seeking to reduce landfill methane emissions (“Methane Rule and Guidelines”)....more
Oilfield operators of every size have been busy implementing the Obama Administration’s labor-intensive requirements to detect and repair vapor leaks from well site equipment, often called the Quad Oa requirements, in...more
A policy memorandum issued by the U.S. Environmental Protection Agency (“EPA”) during December 2017 clarifies how the agency will apply and enforce certain facets of the New Source Review regulations following a pair of...more