News & Analysis as of

Supplemental Environmental Project (SEP) Policy Environmental Violations

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

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Blytheville Steel Mill...

The Arkansas Department of Energy and Environment - Division of Environmental Quality (“DEQ”) and Nucor-Yamato Steel Company (“Nucor”) entered into a March 24th Consent Administrative Order (“CAO”) addressing an alleged...more

Beveridge & Diamond PC

Environmental Enforcement Update: What to Expect In the Second Trump Administration

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We anticipate President Trump’s upcoming term will usher in significant shifts in U.S. environmental enforcement priorities and practices. Beveridge & Diamond has helped clients navigate every change in administration since...more

Beveridge & Diamond PC

Environmental Enforcement Update: Supplemental Environmental Projects and Mitigation in the Second Trump Administration

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Summary/Key Takeaways - In recent years, federal policy on supplemental environmental projects (SEPs)—voluntary and environmentally beneficial projects resulting from negotiation between the government and an alleged...more

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

Supplemental Environmental Project/Air Enforcement: Mississippi Commission of Environmental Quality and Burnsville Silicon...

The Mississippi Commission on Environmental Quality (“MCEQ”) and Mississippi Silicon LLC (“MS”) entered into an August 27th Agreed Order (“AO”) addressing alleged violations of an Air Permit. See Order No. 7349 24....more

Integral Consulting Inc.

Supplemental Environmental Projects: Better than Money and Better Still When Incorporating Justice

Supplemental environmental projects (SEPs) provide one means of addressing environmental violations in alignment with the Biden Administration’s comprehensive environmental justice (EJ) strategy. SEPs were explicitly endorsed...more

Roetzel & Andress

Status of DOJ and EPA Policies on Supplemental Environmental Projects

Roetzel & Andress on

There have been numerous policy changes at the U.S. Department of Justice (“DOJ”) and U.S. EPA during President Biden’s first term. Along with an increased attention to enforcement generally, the policies governing resolution...more

Jones Day

U.S. Intensifies Environmental Crime Enforcement in Puerto Rico and U.S. Virgin Islands

Jones Day on

In Short - The Situation: The U.S. Department of Justice ("DOJ" or "Department") and the U.S. Environmental Protection Agency ("EPA") recently announced the creation of a regional, cross-agency taskforce, targeting...more

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

U.S. Department of Justice Resumption of Supplemental Environmental Projects: National Association of Clean Air Agencies Submits...

The National Association of Clean Air Agencies (“NACAA”) submitted comments on a memorandum issued on May 5th by the United States Department of Justice (“DOJ”) titled: Guidelines and Limitations for Settlement...more

WilmerHale

Supplemental Environmental Projects: Environmental Settlement Tool Poised to Advance Environmental Justice

WilmerHale on

Future federal environmental settlements are likely to include more creative remedies to address the impacts of violations on communities, thanks to recent policy changes at the US Department of Justice (DOJ)....more

Maron Marvel

Department of Justice Revives SEPs as Part of Environmental Justice Enforcement Strategy Roll Out

Maron Marvel on

In recent days, the U.S. Department of Justice (DOJ) has made a series of announcements aimed at addressing environmental justice concerns and enforcement practices. The actions taken by DOJ include the establishment of the...more

Wiley Rein LLP

The Return of the Supplemental Environmental Project

Wiley Rein LLP on

On Thursday, May 5, 2022, the Department of Justice (DOJ) in coordination with the Environmental Protection Agency (EPA) issued a “Comprehensive Environmental Justice Enforcement Strategy” which, most notably, restored the...more

BakerHostetler

Supplemental Environmental Projects Set to Return with New Guidelines

BakerHostetler on

On May 5, Attorney General Merrick Garland announced the return of supplemental environmental projects (SEPs) in U.S. Department of Justice (DOJ) settlements. SEPs are voluntary projects intended to benefit the environment...more

ArentFox Schiff

DOJ Returns to Using Supplemental Environmental Projects Including to Mitigate Harms to EJ Communities

ArentFox Schiff on

On May 5, 2022, the US Department of Justice (DOJ) announced its new environmental justice (EJ) strategy, which has been a priority to the Biden Administration. While the strategy is comprehensive and involves many federal...more

ArentFox Schiff

DOJ Announces Environmental Justice Office and Focused Enforcement Initiative

ArentFox Schiff on

The US Department of Justice (DOJ) released its long-awaited Environmental justice (EJ) enforcement strategy today, a priority for the Biden Administration. The enforcement strategy will “advance environmental justice through...more

Williams Mullen

Biden DOJ Quickly Rescinds Trump Environmental Enforcement Policies

Williams Mullen on

Much attention has been devoted to environmental policies of the prior Trump administration that are likely to be reversed or altered by the new Biden administration. See, e.g., Biden Administration Could Quickly Adopt Many...more

Wiley Rein LLP

In EPA Civil Enforcement, Supplemental Environmental Projects Back on the Table

Wiley Rein LLP on

On Friday, U.S. Department of Justice’s Environment and Natural Resources Division withdrew nine memoranda and policy documents issued by the previous administration related to environmental enforcement. Among those were...more

Pierce Atwood LLP

SEPs Are Back: Biden Administration Rescinds Ban on Supplemental Environmental Projects

Pierce Atwood LLP on

In March 2020, the U.S. Department of Justice Environment and Natural Resources Division (ENRD) issued a memorandum ceasing the use of Supplemental Environmental Projects (SEPs) as part of settlements of federal environmental...more

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

Asbestos Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Sherwood Facility...

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and U.S. Pizza Co., Inc., (“U.S. Pizza”) entered into an October 29th Consent Administrative Order (“CAO”) addressing alleged...more

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

Municipal Stormwater Enforcement: U.S. Department of Justice and City of Colorado Springs, Colorado Enter into Consent Decree

The United States Department of Justice (“DOJ”) entered into an October 29th Consent Decree (“CD”) with the City of Colorado Springs, Colorado (“Colorado Springs”) addressing alleged Clean Water Act National Pollution...more

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

Supplemental Environmental Projects/U.S. Department of Justice: Conservation Law Foundation Files Judicial Challenge to...

The Conservation Law Foundation (“CLF”) filed a Complaint for Declaratory and Injunctive Relief (“Complaint”) in the United States District Court for the District of Massachusetts challenging the Environment and Natural...more

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

Air Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and Pulaski County Steel Pipe...

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and Welspun Tubular, LLC, (“Welspun”) entered into an August 25th Consent Administrator Order (“CAO”) addressing alleged violations...more

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

Supplemental Environmental Project/Hazardous Waste Enforcement: Tennessee Department of Environment and Conservation and Watertown...

The Tennessee Department of Environment and Conservation (“TDEC”) and Moody & Associates, Inc., d/b/a Technical Plating (“Moody”) entered into a Settlement Agreement and Order (“Agreement”) addressing alleged violations of...more

Williams Mullen

Environmental Notes - May 2020

Williams Mullen on

The United States Department of Justice has terminated its policy of allowing companies to perform supplemental environmental projects (SEPs) in lieu of paying civil penalties for violations of federal environmental laws. The...more

Perkins Coie

DOJ Formally Ends Use of Supplemental Environmental Projects in Settlements

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Companies should be aware that Supplemental Environmental Projects (SEPs)—voluntary environmental or public health benefit projects in lieu of payment of civil penalties for violation of federal environmental laws—will no...more

Snell & Wilmer

Trump Eliminates Settlement Tool

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Somewhat lost amidst all the (well deserved) COVID-19 pandemic news that comes out daily, is a decision by the Justice Department regarding the settlement of environmental enforcement cases that will likely have profound...more

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