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The Supreme Court Strips SEC of Fraud-Fighting Forum, Sparking Debate on Broader Implications for Federal Enforcement

For more than a decade, the U.S. Securities and Exchange Commission (the “SEC”) has been able to bring enforcement actions in either federal court or the agency’s internal venue. Not anymore. On June 27, 2024, the U.S....more

The New NEPA Regulations: What You Need to Know About the “Significant Effects” the Final Phase 2 Rule Could Have on Permitting...

On May 1, 2024, the Council on Environmental Quality (“CEQ”) published the final version of Phase 2 of its National Environmental Policy Act (“NEPA”) rulemaking (“Phase 2 Rule”). The Phase 2 Rule is the culmination of the...more

New EPA Greenhouse Gas Rule Takes Aim at Fossil-Fueled Power Plants

The U.S. Environmental Protection Agency (EPA) has finalized a host of new requirements for fossil-fueled power plants, including new source performance standards (“NSPS”) for new and modified coal- and gas-fired plants and...more

EPA Finalizes Revisions to Risk Management Program (RMP) Regulations, with Special Focus on Petroleum and Chemical Manufacturers

The U.S. Environmental Protection Agency (EPA) has issued a final rule (the “Rule”) that substantially expands its Risk Management Program (“RMP”) regulations aimed at preventing chemical accidents. The Rule takes effect on...more

EPA Proposes Rules to Expand its PFAS Authority Under RCRA

On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource...more

A Heavy Lift: EPA Bulks Up Oil and Gas Methane Requirements in New Quad Ob/c Regulations

The Environmental Protection Agency (EPA) has finalized a host of new obligations for upstream and midstream oil and gas owners and operators. These new source performance standards (“NSPS”) and emission guidelines (“EG”) for...more

[CLE Hybrid Event] Making Sense of Methane for the Oil and Gas Sector: EPA’s New Methane Tax, Operating Regulations, and GHG...

The Environmental Protection Agency (EPA) has released proposed and final rules that will regulate methane emissions from oil and gas operations, implement a methane emissions tax, and change greenhouse gas reporting...more

U.S. Fish and Wildlife Service Streamlines Bald and Golden Eagle Protection Act Permitting for Wind Energy and Power Line Projects

On February 12, 2024, the U.S. Fish and Wildlife Service (USFWS) released its final rule revising its permit regulations for “take” under the Bald and Golden Eagle Protection Act (BGEPA), an overhaul that has been several...more

The EPA’s Methane Waste Emission Charge: A Tax by Any Other Name

The Environmental Protection Agency (EPA) has published a proposed rule to assess and collect billions of dollars in methane “waste emission charges” from the oil and gas sector....more

Proposed Sustainable Procurement Revisions to the Federal Acquisition Regulation

As part of its Federal Sustainability Plan, the Biden administration has issued a proposed rule that would revise the Federal Acquisition Regulation (“FAR”) to incentivize federal government buyers to prioritize the...more

Questions Remain After EPA and the Army Corps Update the “Waters of the United States” Definition Following Sackett v. EPA

On August 29, 2023, the Environmental Protection Agency (“EPA”) and U.S. Army Corps of Engineers (“Corps”) released the text of a rule further revising the definition of “waters of the United States” (“WOTUS”) that the...more

V&E Quarterly Securities & ESG Updates - Summer 2023

Welcome to Vinson & Elkins’ Securities and ESG Updates. Our aim is to provide insights into notable developments in securities reporting and the environmental, social and governance space over the quarter and, where...more

President Biden Signs Modest Permitting Reforms Into Law with the Debt Ceiling Bill

On June 3, 2023, President Biden signed into law the Fiscal Responsibility Act of 2023 (“the Act”), which includes modest changes to the National Environmental Policy Act (“NEPA”), among other things. The Act amends NEPA in...more

Environmental Justice Updates: Executive Order 12898 and New Jersey’s Implementation of its Environmental Justice Law

Environmental Justice (“EJ”) continues to be a strong focus of both the federal and state governments with two major developments occurring in the past two weeks. On April 21, 2023, President Biden signed Executive Order...more

By the Numbers: EPA’s Proposal to Regulate 6 PFAS Chemicals From Drinking Water

The Environmental Protection Agency (“EPA”) has proposed regulating six per- and polyfluoroalkyl (“PFAS”) in drinking water under the Safe Drinking Water Act (“SDWA”). In a proposed rule published on March 29, 2023, EPA...more

Environmental Justice 2022 Year-End Review

Environmental Justice (“EJ”) continued to prove a major focus of the Biden administration in 2022. With wide-ranging initiatives across several federal agencies, the administration worked to strengthen enforcement, release...more

Drinking Water Enforcement and Compliance Likely to Remain an EPA Priority

The Environmental Protection Agency (“EPA”) announced it will continue to prioritize enforcement of, and compliance with, the Safe Drinking Water Act (“SDWA”) and federal drinking water regulations through Fiscal Year (“FY”)...more

Elevating EJ: How EPA’s New Environmental Justice Office Raises the Stakes for EJ Enforcement and IRA Funding Opportunities

The Environmental Protection Agency (“EPA”) has launched a new national office tasked with enforcing EPA-related civil rights laws in disadvantaged communities and overseeing billions of dollars earmarked for environmental...more

EPA’s Newest Target for Clean Air Act Enforcement: Stationary Engines

The U.S. Environmental Protection Agency (“EPA”) has announced its latest priority for Clean Air Act enforcement: stationary engines. In an enforcement alert, EPA states that it has been finding numerous violations of Clean...more

EPA Proposes to Designate Two PFAS Chemicals as Hazardous Substances Under CERCLA: Quick Answers to Top Questions

The Environmental Protection Agency (“EPA”) issued a long-anticipated proposal to designate two per- and polyfluoroalkyl substances (“PFAS”) as hazardous substances under the federal Superfund law known as the Comprehensive...more

EPA Proposes Expansion of Risk Management Program Requirements, with Special Emphasis on Petroleum, Coal, and Chemical...

The U.S. Environmental Protection Agency (“EPA”) has proposed substantial changes to its Risk Management Program (“RMP”) regulations aimed at preventing chemical facility accidents, a move that will affect industrial...more

PHMSA’s Mega Rule Is Complete: Here’s What You Should Know

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) recently released the final rule in a rulemaking trilogy collectively known as the “Mega Rule” — a set of regulations designed to improve pipeline safety by...more

What Does the Supreme Court’s Recent Decision on Climate Regulation Mean for the Energy Industry?

The Supreme Court ended its 2021 term with a much-anticipated decision in West Virginia v. EPA.1 The 6-to-3 decision held that the Environmental Protection Agency (“EPA”) does not have the authority under Section 111(d) of...more

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