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Climate Change, Environmental Justice, and Process Safety: EPA Proposes Risk Management Program Rule Amendments (Updated)

The U.S. Environmental Protection Agency (EPA) has proposed to further amend its Clean Air Act Risk Management Program (RMP) rules and has issued a proposed rule. 87 Fed. Reg. 53556 (August 31, 2022). The proposed rule would...more

COVID-19 Impacts in Massachusetts: Entering Phase 3 and Restarting the Clock on State Permitting

Update Highlights: Massachusetts moves into Phase 3 of its reopening plan on July 6, including the opening of fitness centers and health clubs, museums and aquariums, movie theaters and performance halls (at limited...more

COVID-19 Impacts in Massachusetts: State Courts to Begin Reopening on July 13; Tolling Ends June 30

This and other updates on the Commonwealth’s response are collected on its website and the separate court system site. Beveridge & Diamond’s COVID-19 EH&S Resource Center is available as we work remotely throughout our seven...more

EPA Policy Provides Enforcement Relief Where Needed Due to Pandemic

On March 26, 2020, EPA issued new guidance addressing a range of issues relating to environmental compliance and enforcement during the COVID-19 pandemic. The Agency sets expectations for the regulated community to continue...more

Clean Air Act Single Source Determinations: This Time, Adjacent Means Adjacent!

The definition of a “source” is the foundation of air permitting. Yet for many years, one of the most vexing questions has been how to determine which air emission sources located near each other and under common ownership or...more

EPA Rescinds Obama-Era RMP Rule

Nearly three years after adopting extensive amendments to its rules on accidental release prevention under the Clean Air Act, the Environmental Protection Agency (EPA) adopted a final rule rescinding nearly all of the...more

NRDC Files Court Challenge to Revived NSR Rule Almost a Decade After EPA First Published Its Project Aggregation Rule

After 10 years on ice, EPA’s 2009 project aggregation rule may finally see its day in court. On Monday, January 14, 2019, NRDC filed a petition for judicial review of EPA’s recent revival of a 2009 Rule that amended EPA’s...more

Obama Era RMP Rule Amendments Effective December 3, 2018, For Now…

In the final days of the Obama administration, the Environmental Protection Agency (EPA) adopted a package of revisions to its Accident Prevention/Risk Management Plan rules under the Clean Air Act at 40 CFR Part 68 (the RMP...more

EPA Proposes to Rescind RMP Provisions Amended Under Obama Administration, Seeks Comments

On May 30, 2018, the U.S. Environmental Protection Agency (EPA) published a proposed rule (Proposed Rule) that would rescind the majority of the amendments to the RMP rule that were finalized in January 2017 in the final days...more

Environmental Enforcement Policy Developments: The Trump Administration and Congress Make Their Mark

During the past year, numerous developments have signaled a change in approach to environmental enforcement as it is being conducted by the Trump Administration. Enforcement continues, in several cases on high profile...more

MassDEP Issues Air Rule Amendments

Culminating a two-year rule promulgation process, MassDEP has issued a final rule amendment package that makes adjustments to numerous provisions of the Massachusetts air regulations. The announced purpose of this package...more

EPA Region 1 Increasingly Targeting Ammonia Refrigeration Processes for RMP and General Duty Clause Enforcement

Over the course of 2017, U.S. EPA Region 1 has settled several significant enforcement matters arising under the risk management provisions of the Clean Air Act, Section 112(r). The risk management requirements are intended...more

EPA Delays Effective Date of RMP Rule Amendments, Environmental Groups File Challenge

On June 14, 2017, EPA published a final rule in the Federal Register delaying the effective date of its Risk Management Program (RMP) rule amendment package for twenty months, until February 19, 2019. EPA’s decision was...more

D.C. Circuit Signals Limits on EPA’s Authority to Reduce Requirements in Existing Environmental Rules: Waterkeeper Alliance v. US...

As the Trump Administration seeks to re-write many of the nation’s environmental rules, the U.S. Court of Appeals, District of Columbia Circuit, has issued a decision in Waterkeeper Alliance v. US EPA that signals the...more

OMB Signs Off on U.S. EPA’s 2017 Construction Stormwater Permit

Spared by the Office of Management and Budget from the Trump Administration’s regulatory freeze, the U.S. Environmental Protection Agency’s (EPA) 2017 National Pollutant Discharge Elimination System General Permit for...more

EPA Stays RMP Rule Amendments and Grants Petition for Reconsideration

The U.S. Environmental Protection Agency has stayed the implementation of a significant revision of the Risk Management Program (RMP) rule pending the receipt of additional comments. Simultaneously, EPA has granted a request...more

Massachusetts Environmental and Land Use Alert

Off to Court We Go: Petitioners Challenge EPA’s Small MS4 General Permit for Massachusetts - The storm of debate and criticism over the terms and conditions of the U.S. Environmental Protection Agency’s (EPA) General...more

“Oh The Times . . . They are A-Changing:” EPA & DOJ Follow Through on Worker Endangerment Initiative

On October 12, 2016, the U.S. Department of Justice (“DOJ”) announced that four Texas companies agreed to plead guilty to criminal violations of the Clean Air Act at oil and chemical processing facilities, and to collectively...more

Stormwater Forecast: Prepare for More Aggressive Benchmark Monitoring and Corrective Action Requirements under the Next Proposed...

EPA is expected to propose a revised system of benchmark monitoring and corrective action requirements to replace those of the current 2015 Multi-Sector General Permit for Stormwater Associated with Industrial Activities...more

Does Your Toxic Release Inventory Make You a Target for Enforcement?

Summary: The U.S. Environmental Protection Agency’s Office of the Inspector General is examining the Agency’s usage of Toxic Release Inventory data to evaluate companies’ compliance with surface water discharge permitting...more

New Conservation Restrictions for the Northern Long-Eared Bat Will Have Limited Impact on Development in Massachusetts

A new Endangered Species Act rule protecting the northern long-eared bat will likely have only limited impact on development and land use activities in Massachusetts due to fairly specific restrictions imposed by the final...more

EPA Issues Proposal to Amend RMP Rule

The U.S. Environmental Protection Agency (EPA) has released a long awaited proposal to update the Accidental Release Prevention rules at 40 C.F.R. Part 68, which implement the Clean Air Act Section 112(r)(7) risk management...more

EPA Proposes Numerous Changes to Greenhouse Gas Reporting Rule

On December 21, 2015, the EPA Administrator signed off on a fairly lengthy package of proposed changes to the GHG Reporting Rule, 40 CFR Part 98, and the proposal will be published soon in the Federal Register. There will be...more

EPA Publishes Clean Power Plan And Initiates Concerted Attempt to Reduce GHG Emissions from Fossil Fuel Fired Power Plants

The Clean Power Plan is one of the most intensely scrutinized and debated rules in EPA’s history. The proposed rule, published in June of 2014, generated 4.3 million individual comments. The final rule was immediately...more

Multi-Sector General Permit for Stormwater Discharges – Newly Issued and Newly Challenged

U.S. EPA issued a new Multi-Sector General Permit for Stormwater Discharges from Industrial Activities on June 4, 2015, replacing the 2008 general permit, which expired in September 2013 and had been administratively...more

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