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Effective Immediately: Agencies Mirror Sackett Restrictions For WOTUS

The U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers (together, the Agencies) issued a straight-to-final-rule revised definition of “waters of the United States” (WOTUS) on August 29, 2023. This...more

Supreme Court Narrows CWA Jurisdiction Over Waters of the U.S.

On May 25, the U.S. Supreme Court issued its long-awaited decision in Sackett v. EPA, No. 21-454, holding that Clean Water Act (CWA) jurisdiction extends to wetlands only if they have a continuous surface connection to...more

Clean Water Act Jurisdiction Over Waters of the U.S. Redefined Yet Again

On December 30, 2022, the U.S. Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (USACE) announced a final rule once again updating the definition of “waters of the United States” (WOTUS) and,...more

Army Corps Signals Narrowing Nationwide Permit 12

The U.S. Army Corps of Engineers (Corps) recently published notice that it is initiating a formal review of Nationwide Permit (NWP) 12 a little over a year after its latest iteration took effect. NWP 12, which serves as a...more

U.S. Supreme Court Positioned to Finally Resolve Scope of Federal Jurisdiction Over Remote Wetlands

On January 24, 2022, the U.S. Supreme Court (SCOTUS) granted review of Sackett v. EPA, apparently with the sole purpose of deciding once and for all “the proper test for determining whether wetlands are ‘waters of the United...more

Arizona Court Vacates Navigable Waters Protection Rule: What it Means for Your Project

In a recent decision, a federal judge in Arizona vacated the Trump Administration’s Navigable Waters Protection Rule (NWPR) and remanded the rulemaking back to U.S. Environmental Protection Agency and the U.S. Army Corps of...more

Biden Administration Proposes a Reset on Defining “Waters of the U.S.”

Over the past week, the U.S. Environmental Protection Agency and the U.S. Army Corps of Engineers announced plans to undo the Trump administration’s Navigable Waters Protection Rule, and take the Biden administration’s next...more

FERC Adopts Final Rule Formalizing One-Year Deadline for States To Issue Clean Water Act Certifications; Second Circuit Affirms...

On March 18, 2021, the Federal Energy Regulatory Commission (FERC) adopted a Final Rule requiring state agencies to issue Clean Water Act (CWA) Section 401 water quality certificates within one year of receiving a request or...more

FERC Proposes One-Year Deadline for States to Issue Clean Water Act Certifications

Acting in response to a Trump Administration Executive Order instructing federal agencies to reduce regulatory uncertainties and expedite construction of energy infrastructure, the Federal Energy Regulatory Commission (FERC)...more

President Trump Orders Expanded Use of Emergency Powers to Streamline Infrastructure

On Thursday, June 4, 2020, President Trump signed an Executive Order (EO) on “Accelerating the Nation’s Economic Recovery from the COVID-19 Emergency by Expediting Infrastructure Investments and Other Activities.” Relying on...more

Federal Court Nullifies Clean Water Act General Permit for Pipelines and Other Linear Projects

In an order with serious and immediate national implications for the construction of pipelines, electrical lines, fiber optic cable, and other utility projects, a Montana federal court has vacated Clean Water Act (CWA)...more

New WOTUS Rule Clarifies Clean Water Act Jurisdiction, Awaits Litigation

On January 23, 2020, the U.S. Environmental Protection and U.S. Army Corps of Engineers finalized a long-awaited new rule redefining the term “Waters of the United States” (WOTUS) under the Clean Water Act (CWA). The Agencies...more

Déjà Vu: EPA, Army Corps Take First Step to Redefine “Waters of the U.S.”

Last week EPA and the U.S. Army Corps of Engineers announced that they again will be taking the first step in the long-awaited rulemaking process to redefine the scope of “waters of the United States” (WOTUS) under the...more

New EPA Section 401 Guidance Clarifies Timelines for and Scope of Certification Reviews

On June 7, 2019, the U.S. Environmental Protection Agency (EPA) issued nonbinding guidance clarifying and providing recommendations regarding the implementation of Section 401 of the Clean Water Act, 33 U.S.C. § 1341. Most...more

Executive Orders Aim to Streamline Energy Infrastructure Projects 

On April 10, 2019, President Trump signed two executive orders intended to address a range of legal and procedural hurdles commonly facing infrastructure projects, particularly in the energy sector. Most notably, the...more

EPA and Army Corps Again Propose to Redefine Waters Regulated Under the Clean Water Act

On December 11, 2018, the U.S. Environmental Protection Agency and Army Corps of Engineers (the “agencies”) announced once again that they are proposing a new rule to redefine the scope of waters and wetlands subject to...more

Justices Request the Government’s Views on CWA Discharge Cases

On December 3, 2018, the U.S. Supreme Court requested the federal government’s views on two petitions for certiorari asking the Court to decide whether the Clean Water Act (CWA) regulates releases of pollutants that reach...more

“WOTUS”: A Tale of Two Rules While Litigation and Rulemaking Continue

On August 16, 2018, the U.S. District Court for the District of South Carolina issued a nationwide injunction on a Trump administration rule that has been preventing the 2015 rule that revised the definition of “waters of the...more

Petitions Seek Supreme Court Review of Fourth and Ninth Circuit Decisions That Could Expand the CWA’s NPDES Program

Earlier this year, the Fourth and Ninth Circuits decided a pair of cases that have the potential to greatly expand the scope of the National Pollution Discharge Elimination System (NPDES) permit program under the Clean Water...more

Cert Petition Seeks Supreme Court Review of Ninth Circuit’s Expansion of the CWA’s NPDES Program

On February 1, 2018, the Ninth Circuit issued a decision in Hawai’i Wildlife Fund, 886 F.3d 737 (9th Circ. 2018), that has the potential to greatly expand the scope of the National Pollution Discharge Elimination System...more

Unanimous Supreme Court: WOTUS Rule Challenges Belong in Federal District Courts

In a unanimous opinion, the Supreme Court today held that lawsuits challenging the 2015 rule amending the definition of waters of the United States (WOTUS Rule) under the Clean Water Act (CWA) must be brought in federal...more

Replacement of the Clean Water Rule to Be a Two-Step Process

The Environmental Protection Agency and Army Corps of Engineers announced yesterday that the implementation of President Trump’s executive order directing EPA and the Corps to replace the Clean Water Rule will be a two-step...more

WOTUS Litigation Update: Confusion Breeds Confusion

Perhaps it is poetic justice. The litigation over the final Waters of the United States (WOTUS) rule is as disjointed and confusing as the rule itself. Following a key court ruling yesterday, the WOTUS rule is now...more

EPA, Army Corps Redefine Clean Water Act Jurisdiction

The Environmental Protection Agency and the Army Corps of Engineers (“the agencies”) have issued the long-awaited final rule to define the scope of waters and wetlands subject to federal jurisdiction under the Clean Water Act...more

Wotus: Scotus, Potus . . . Lotus?

It was inevitable I suppose. In a town where every policy discussion reaffirms the lampooning it receives in HBO’s “Veep,” it was only a matter of time until the EPA/Army Corps’ proposed rule on the scope of jurisdiction...more

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