On Friday, the D.C. Circuit reinstated the affirmative defense for emergency situations resulting in exceedances of emission limitations in Clean Air Act Title V operating permits. That defense, available in the Title V...more
The United States Environmental Protection Agency (“EPA”) published an April 29th Federal Register Notice stating it was considering alternative interpretations regarding affirmative defenses in Clean Air Act State...more
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