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EPA Doubles Down on Enforcement to Address Climate Change

In its latest move to address climate charge, the Environmental Protection Agency’s (EPA) Office of Enforcement and Compliance Assurance (OECA) on September 28, 2023 issued a memorandum titled “EPA’s Climate Enforcement and...more

Tenth Circuit Ruling on Temporary Emissions in Colorado Will Have Widespread Impacts on Air Permitting in Western States

In a decision with implications for air permitting across the West, a divided three-judge panel of the Tenth Circuit Court of Appeals vacated and remanded EPA’s approval of Colorado’s state implementation plan (SIP) based...more

GHG Standards for the Power Sector: Is Third Time the Charm or Is It Déjà Vu?

In the third attempt in less than 10 years, the Environmental Protection Agency issued a proposed rule package (“Proposal”) that would apply strict greenhouse gas emissions standards to the fossil fuel-fired power sector. The...more

Impacts on the Western US from EPA Proposed Strengthening of Annual PM2.5 NAAQS

On January 6, 2023, EPA released a pre-publication version of its highly anticipated proposal to strengthen the National Ambient Air Quality Standard (“NAAQS”) for fine particulate matter or PM2.5, one of two classes of...more

EPA Super Sizes Proposal to Crack Down on Methane from Oil and Gas Sector

This article is the second in a two-part series analyzing recent proposals by federal agencies to reduce methane emissions from oil and gas production. The first article addresses the Bureau of Land Management’s (BLM)...more

EPA Applies More Rigorous Emission Controls on Uintah and Ouray Indian Reservation Lands

EPA is poised to publish a final Federal Implementation Plan (FIP) for emissions from oil and natural gas sources on Indian country lands within the Uintah and Ouray Indian reservation in northeast Utah. EPA recently released...more

The Future of Federal Agency Rulemakings After West Virginia v. Environmental Protection Agency

The US Supreme Court’s 6-3 decision in West Virginia v. EPA, 597 US ___ (2022), narrowly defined the scope of the Environmental Protection Agency’s (EPA) statutory authority to regulate greenhouse gas emissions from...more

Buckle Up for the SEC's Mandatory Climate Change Reporting Ride

On March 21, 2022, the US Securities and Exchange Commission (the "SEC") proposed rules governing the "Enhancement and Standardization of Climate-Related Disclosures for Investors." ...more

Policy Review Heats Up Under New EPA Administrator Regan

The swearing-in of Michael Regan as EPA Administrator means that open questions on policy, agenda-setting, and prioritization for the Agency will soon be answered. Issues that have risen to the top of the new EPA...more

Assessing Climate Cost in Policy Decisions

Right out of the box, the Biden Administration took a decisive stance on the importance of climate costs in agency decision making, returning to Obama-era metrics and values. On his first day in office, President Biden issued...more

EPA Proposes to Retain Particulate Matter Standards of Importance to Industries in Arid West

On April 14, 2020, the Environmental Protection Agency (EPA) proposed to retain the current National Ambient Air Quality Standards (NAAQS) for particulate matter, including both the PM10 and PM2.5 standards. The PM10 and...more

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