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The Trump Administration: Developments in Environmental Policy

From the outset, key goals of the incoming Trump Administration have been: supporting fossil fuel development, ending incentives for renewable energy and energy transition, removing burdensome environmental regulations and...more

Incoming Environmental Protection Agency (EPA) Personnel and Impact on Enforcement

To nobody’s surprise, it is already evident that President Trump’s second term will mark a significant shift in environmental regulation and policy from the Biden Administration. This article marks the first in a where we...more

Wetlands No More? U.S. Supreme Court Limits Federal Regulation of Wetlands in Sackett v. EPA Decision

On May 25, 2023, the Supreme Court issued a decision in Sackett v. EPA,effectively narrowing the scope of federally protected wetlands to which the Clean Water Act (CWA) applies. The CWA provides the U.S. Army Corp of...more

The Biden Administration Proposes New Rule to Dramatically Cut Methane Emissions in the Oil and Gas Sector

Last week, as world leaders met at the United Nations Climate Change Conference (COP26) in Glasgow, Scotland, the U.S. Environmental Protection Agency (“EPA”), issued a proposed rule under the Clean Air Act (“CAA”) designed...more

“Where’s the PFAS?” EPA Expands Search for PFAS in the Marketplace

On June 10, 2021, pursuant to Section 8(a) of the Toxic Substances Control Act (“TSCA”), the U.S. EPA proposed a rule requiring manufacturers and importers of per- and polyfluoroalkyl substances (“PFAS”) to report information...more

An End to Draining the Swamp? U.S. EPA, Army Corps Announces Intent to Revise Definition of “Waters of the United States”

Yesterday, the U.S. EPA and the U.S. Army Corps of Engineers announced their intent to initiate a rulemaking process to promulgate a new definition of “waters of the United States” (“WOTUS”) under the Clean Water Act (“CWA”)....more

PBT Regulations Update - No Action Assurance for PIP (3:1) Articles and New Request for Comments

After a recent flurry of concerns over the potential for widespread supply-chain interruptions, the United States Environmental Protection Agency (“EPA”) issued a 180-day No Action Assurance (NAA) regarding the new...more

U.S. EPA Extends TSCA CDR Reporting Deadline to January 29, 2021

Every four years, under the Chemical Data Reporting (CDR) Rule issued pursuant to the Toxic Substances Control Act (TSCA), manufacturers (including importers) must provide U.S. EPA with information on the production and use...more

Deadline Approaching: TSCA CDR Reports Due November 30, 2020

Every four years, under the Chemical Data Reporting (CDR) Rule issued pursuant to the Toxic Substances Control Act (TSCA), manufacturers (including importers) must provide U.S. EPA with information on the production and use...more

U.S. EPA Issues Enforcement Discretion Policy Addressing Coronavirus Compliance Impacts

On Thursday, March 26, the United States Environmental Protection Agency (“U.S. EPA”) released a much anticipated enforcement discretion policy that provides temporary and limited enforcement discretion for certain violations...more

Managing the Commercial Impact of the Coronavirus: Top Environmental Considerations

Even though the coronavirus poses novel and complex challenges to all aspects of a company’s operations, it is not an excuse for companies to press “pause” on their obligations to comply with environmental laws and permits. ...more

Updated TSCA Inventory: What You Need to Know Now to Avoid Business Disruption*

In 2016, after decades without any changes, Congress amended the Toxic Substances Control Act (the “TSCA”) with an eye towards updating and modernizing the regulatory regime for chemical substances. One of the elements of the...more

Updated TSCA Inventory: What You Need to Know Now to Avoid Business Disruption

In 2016, after decades without any changes, Congress amended the Toxic Substances Control Act (the “TCSA”) with an eye towards updating and modernizing the regulatory regime for chemical substances. One of the elements of the...more

Medication or Hazardous Waste? EPA Creates Significant New Requirements for Managing Unused Pharmaceuticals

On December 11, 2018, U.S. EPA Acting Administrator Andrew Wheeler signed a new hazardous waste pharmaceutical rule. The final rule retains a proposed requirement, opposed by industry, that prescription pharmaceuticals sent...more

Feeling Inundated? EPA Swamps the WOTUS Rule, Proposes New Definition of “Waters of the U.S.”

Fulfilling one of President Trump’s campaign promises, on December 11, 2018, the U.S. Environmental Protection Agency (EPA) and the U.S. Department of the Army (the Corps) signed a proposed rule to limit the scope of the...more

Medication or Hazardous Waste?

While much of the environmental bar was focused on the Waters of the U.S. rulemaking, on December 11, U.S. EPA Acting Administrator Andrew Wheeler signed the new hazardous waste pharmaceutical rule. The final rule retains a...more

President Trump Curbs Controversial WOTUS Rule

Two days ago, President Trump issued an executive order (Order) that will scale back the U.S. Environmental Protection Agency’s (EPA) and U.S. Army Corps of Engineers’ (Corps) hotly contested “waters of the United States”...more

The Toxic Substances Control Act Overhaul: What You Need to Know

On June 22, 2016, President Obama signed the “Frank R. Lautenberg Chemical Safety for the 21st Century Act” into law, making comprehensive changes to the Toxic Substances Control Act (TSCA). This step comes after years of...more

Testing the Waters: The U.S. Supreme Court Agrees to Hear U.S. Army Corps’ Clean Water Act Determinations Challenge

On December 11, the U.S. Supreme Court agreed to hear a challenge to the Eighth Circuit’s April 2015 ruling that U.S. Army Corps of Engineers’ (Army Corps) jurisdictional determinations are final agency actions subject to...more

“Clearing” the Waters – U.S. EPA and the Army Corps Finalize “Waters of the United States” Definition

On May 27, 2015, the United States Environmental Protection Agency (“U.S. EPA”) and the United States Army Corps of Engineers (“Corps”) issued their highly anticipated final revision to the definition of “waters of the United...more

EPA Advocacy Can Add Value to a Manufacturer’s Bottom Line

Whether you’re manufacturing widgets or rubber bands, paper products or cheese, one thing most manufacturers have in common is being subject to various regulations by the Environmental Protection Agency (EPA). Manufacturers...more

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