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Tracking Update: Trump Administration's Latest Deregulatory Actions on Energy, Environment and Natural Resources

President Trump has issued a flurry of new Executive Orders and Presidential Memoranda aimed at advancing the Administration’s deregulatory agenda, particularly in the energy and environmental sectors. This advisory provides...more

Key Takeaways on Updated EPA Enforcement Priorities

On the heels of its March 12 major announcement about 31 deregulatory actions, EPA also issued an important Memorandum honing the National Enforcement and Compliance Initiatives (NECI’s) adopted under the Biden administration...more

Preparing for a Wave of Citizen Suits in Texas – Ten Tips for Protecting Sensitive Information from Disclosure Under the Texas...

As earlier reported, companies should expect environmental non-governmental organizations (eNGOs) to file a barrage of citizen suits to supplement the rollback of U.S. Environmental Protection Agency (EPA) enforcement cases...more

Key Areas for Regulatory Engagement With the Trump Administration’s Emphasis on Biofuels

Overview - Among its energy policy priorities, early executive orders, and other actions, the Trump administration has reinforced its commitment to expanding the U.S. biofuels sector, which typically has strong bipartisan...more

What to Do If You Get a Notice of Intent to Sue from an eNGO

Most federal environmental statutes grant citizens broad authority to bring lawsuits against companies where there is alleged noncompliance. Before they can do so, however, they must provide a Notice of Intent (NOI) to sue....more

President Trump Mandates Unprecedented Agency Review of Rules and Enforcement Actions

As companies and others in the regulated community continue to evaluate their strategies in light of the Trump administration’s rollout of its deregulatory agenda, we highlight a notable executive order (EO), Executive Order...more

The Citizens Are Coming: Citizens Groups Are Better Funded Than Ever and Will Take Over Where Biden Left Off (Updated)

We expect newly-confirmed U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin to quickly follow through on President Trump’s promises to draw down federal enforcement efforts. In a stark directive, Trump has...more

Ten Strategies to Use When eNGOs FOIA EPA to Prepare for Citizen Suits

Environmental non-governmental organizations (eNGOs) looking to develop citizen suits typically first mine publicly available compliance information companies must submit to state and federal environmental agencies. eNGOs...more

The Citizens Are Coming: Citizens Groups Are Better Funded Than Ever and Will Take Over Where Biden Left Off

We expect newly-confirmed U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin to quickly follow through on President Trump’s promises to draw down federal enforcement efforts, particularly in the arena of air...more

Outlook for Trump Administration Environment, Energy, and Natural Resource Regulation, Enforcement & Litigation

Overview - Following our post-election Alert outlining major anticipated themes for environmental and natural resource law and policy in the second Trump administration, leaders from a number of our practices – many of...more

Four Strategies and Five Legal Arguments To Defend Your Company Against EPA’s Benzene Enforcement Initiative

The U.S. Environmental Protection Agency’s (EPA) latest attempt to replace rulemaking with enforcement is in full force, notwithstanding a spate of historic Supreme Court decisions reflecting keen frustration with federal...more

Implications of Recent Supreme Court Decisions on Administrative, Environmental and Natural Resources Law

The final days of the U.S. Supreme Court’s 2023 term saw the release of several decisions that may – or may not, depending on one’s perspective and desired strategy – hold significant implications for administrative law...more

EPA’s Proposed NSR Rule for Project Emissions Accounting Will Mean Permitting Delays for Projects and Expansions

Key Takeaways - What Happened? On May 3, 2024, the U.S. Environmental Protection Agency (EPA) published its proposal to revise the Clean Air Act’s (CAA) New Source Review (NSR) preconstruction permitting program...more

EPA Issues Enforcement Alert Targeting BWON and QQQ Noncompliance at Refineries and Chemical Manufacturers

The U.S. Environmental Protection Agency’s (EPA) Office of Civil Enforcement recently published an Enforcement Alert with the purported objective of “reminding” companies of their compliance obligations under the Benzene...more

Supreme Court Update: How Would Changes to Chevron Deference Affect EPA Risk Analyses

In Brief: Entities subject to EPA regulation are closely watching the U.S. Supreme Court’s potential reframing of the Chevron deference doctrine. But they should also pay close attention to EPA’s extra-regulatory scientific...more

EPA’s New “Public Participation” Threshold for an “Applicable Requirement” Would Create New Complexities for Clean Air Act Title V...

On January 9, 2024, the U.S. Environmental Protection Agency (EPA) proposed amendments to its Clean Air Act (CAA) Title V operating permit rules to clarify the scope of an “applicable requirement” that can be implemented...more

EPA Finalizes Air Rule Targeting Oil and Gas Industry Methane Emissions: Final Rule Includes New Source Performance Standards for...

Key Takeaways - • What Is Happening? On December 2, 2023, during the United Nations Climate Change Conference (COP28), the U.S. Environmental Protection Agency (EPA) announced a final Clean Air Act (Act) rule designed to...more

It’s Not Your Imagination: It’s Getting Even Harder to Permit Your Project In Texas

Companies seeking air quality permits or permit amendments for construction of new projects under the Texas Clean Air Act’s New Source Review (NSR) program should note recent court decisions at federal, state, and...more

Prepare Now for Even More Aggressive EPA Enforcement

Companies should take note and be prepared to respond quickly to more—and more aggressive—EPA enforcement, on the heels of two new enforcement initiatives announced by David Uhlmann, the recently confirmed Assistant...more

EPA Leverages Controversial IRIS Value for Ethylene Oxide to Fast-Track Overhaul of Clean Air Act Regulations of Chemical...

Last week, the U.S. Environmental Protection Agency (EPA) issued a 444-page pre-publication summary of new proposed rules intended to reduce hazardous air emissions from chemical manufacturers in the Synthetic Organic...more

Brazil Updates: Biden and Lula Advance Environmental and Climate Agendas, Brazil Makes Progress on Other Chemical Regulatory...

The Brazilian government continues to fulfill its early commitment to combat the climate crisis, end deforestation, promote sustainable development, and enable energy transition, maintaining the trend reported in our two news...more

Brazil Continues to Implement Social, Environmental, and Climate Change Regulatory Reforms

In line with our November 2022 news alert, Brazil’s new administration has had a very busy January pursuing its social, environmental, and climate agendas. In his first week in office, President Luiz Inácio Lula da Silva...more

New Plastics Bill Would Place a Moratorium on All Permits for New Plastics Facilities Until Massive Slate of New Environmental...

The Protecting Communities from Plastics Act (S. 5163/H.R. 9388), introduced late last week by Senator Cory Booker (D-NJ), Representative Jared Huffman (D-CA-02), Senator Jeff Merkley (D-OR), and Representative Alan Lowenthal...more

Methane Emissions in the Spotlight at COP27: EPA Proposes for Comment Enhanced Methane Regulations and A Novel Super-Emitter...

Key Takeaways & Analysis - During the COP27 meeting of the UN Climate Change Convention, President Biden unveiled significant proposed enhancements to the Administration’s existing methane regulation program, including a...more

TCEQ Announces New Public Involvement Plan

Starting November 1, 2022, Texas Commission on Environmental Quality (TCEQ) will require applicants who are applying for a new registration, permit, or activity, or making certain changes to an existing registration, permit,...more

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