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DOJ Plans Sweeping Reorganization of ENRD

The US Department of Justice (DOJ) is planning a major reorganization of the Environment and Natural Resources Division (ENRD) that includes consolidating several sections within the division into other DOJ divisions, as well...more

CARB Relaxes Carbon Emission Reporting Requirements and Seeks Comment on Reporting and Risk Disclosure Requirements

The California Air Resources Board (CARB) announced this month that it will use enforcement discretion for the first greenhouse gas (GHG) emission reports due in 2026 to allow regulated businesses (doing business in...more

California Enacts New Law Imposing Additional Restrictions on Warehouses

Environmental regulations targeting potential impacts of warehousing facilities continue to be in the spotlight. On September 29, California Governor Gavin Newsom signed AB 98 into law, imposing new siting restrictions and...more

ESG Update: Congress Questions Whether ESG-Related Coalitions Violate Antitrust Laws

Republican lawmakers are continuing their antitrust push against environmental, social, and governance (ESG) investor initiatives by investigating a prominent climate coalition that is focused on getting companies to curb...more

EPA Approves South Coast Air Quality Management District’s Warehouse Indirect Source Rule

On September 11, the US Environmental Protection Agency (EPA) took final action approving a revision to California’s State Implementation Plan (SIP) to include the South Coast Air Quality Management District’s (SCAQMD)...more

SEC v. Jarkesy’s Implications for Environmental Enforcement Actions

On June 27, the US Supreme Court issued an opinion in SEC v. Jarkesy that limits the US Securities and Exchange Commission’s (SEC) ability to administratively seek civil penalties against defendants for securities fraud....more

EPA Updates Interim Guidance on Destruction and Disposal of PFAS Wastes

On April 8, the US Environmental Protection Agency (EPA) issued interim guidance for public comment regarding the destruction and disposal of per- and polyfluoroalkyl substances (PFAS). Below, we discuss the guidance and...more

EPA Finalizes Rule Designating Two PFAS as Hazardous Substances Under CERCLA and Issues PFAS Enforcement Policy

Earlier this week, the US Environmental Protection Agency (EPA) finalized a new rule designating two per- and polyfluorinated substances (PFAS), perfluorooctanoic acid (PFOA) and perfluorooctanesulfonic acid (PFOS), as...more

Is the Robinson-Patman Act Returning? Or Was It Never Really Gone?

The Federal Trade Commission (FTC) has heralded its increased antitrust scrutiny of price discrimination under the Robinson-Patman Act (RPA), though little has come of it to date. Yet, our review of trends in private...more

EPA Finalizes National Primary Drinking Water Regulation for Six PFAS

On April 10, the US Environmental Protection Agency (EPA) announced its final PFAS drinking water rule, setting new drinking water standards for six per- and polyfluoroalkyl substances (PFAS). ...more

SEC Approves Climate-Related Disclosure Requirements

On March 6, the US Securities and Exchange Commission (SEC) approved new rules requiring public companies to disclose extensive climate-related information in their registration statements and periodic reports. The SEC has...more

EPA Finalizes Changes to the Clean Air Act’s Risk Management Program

On March 1, the US Environmental Protection Agency (EPA) announced finalized amendments to the Clean Air Act’s Risk Management Program (RMP) through the Safer Communities by Chemical Accident Prevention Rule (Final...more

New Jersey Enacts Extended Producer Responsibility Law For Electric Vehicle Batteries

One of the recent efforts to promote the circular economy has included Extended Producer Responsibility (EPR) laws that give manufacturers responsibility for managing the waste associated with their products beyond the point...more

Warehouse and Logistics Operations Targeted by Regulatory Push for “Indirect Source Rules” Targeting Vehicle Emissions

Historically, regulations under the federal Clean Air Act (CAA) and related state laws divided the world into “stationary” and “non-stationary sources.” “Stationary sources” included facilities like power plants and factories...more

New Federal Climate Change Guidance for Large Banks Outlines Risk Management Framework

On October 24, US banking regulators, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation (the “agencies”), issued long-awaited guidance...more

Biden Administration Proposes Significant Changes to Regulations Implementing the National Environmental Policy Act

The energy transition and increased public focus on environmental issues have strained the existing regulatory regime including the National Environmental Policy Act (NEPA). NEPA directs agencies to conduct environmental...more

EPA Removes Emergency Affirmative Defense for Title V Air Permits

On July 21, 2023, the US Environmental Protection Agency (EPA) issued a long-awaited final rule that will make it difficult for sources to continue to rely on an “emergency” to avoid liability for permit violations under...more

Supreme Court Pulls Back Dormant Commerce Clause in National Pork Producers Council v. Ross

Federalism — the allocation between federal and state governments — is at the heart of American constitutional law. In a dispute related to the constitutionality of California state regulations dealing with pig farming, the...more

ESG Litigation Update: Antitrust Claims

Environment, social, and governance (ESG) considerations related to investment and corporate governance have made front-page news in recent months, as US elected officials debate whether industry-related ESG practices may...more

DOJ Antitrust Division Announces Withdrawal of Information Sharing Safety Zone

On February 2, 2023, Principal Deputy Assistant Attorney General Doha Mekki announced that the US Department of Justice (DOJ) Antitrust Division was revisiting and withdrawing several policy statements that provided a key...more

Fourth Circuit Precludes NGO Challenge to Trump Administration NEPA Rules as Biden Administration Promulgates Replacements

These days, environmental policy is often established indirectly. While “Schoolhouse Rock” may have taught some of us “How a Bill Becomes a Law,” its insights are less relevant in the current era where things like purportedly...more

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