The EPA on July 2 issued a finalized interim rule, published six days later in the Federal Register, which delays implementation of certain National Emission Standards for Hazardous Air Pollutants (NESHAP) requirements for...more
The American Chemistry Council (“ACC”) and American Fuel & Petrochemical Manufacturers (“AFPM”) sent a March 31st letter to the United States Environmental Agency (“EPA”) requesting: …a two-year exemption from the...more
Every law student learns that the Administrative Procedure Act (APA) outlines the default rules for how federal agencies propose and finalize regulations and how courts review them. But for many significant actions under the...more