News & Analysis as of

Environmental Liability Discharge of Pollutants

Pullman & Comley, LLC

Forever Chemicals Present Significant Challenges for Commercial Real Estate

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In recent years, PFAS — or “forever chemicals” — have emerged as a major topic of concern for landowners, business owners and environmental and real estate professionals as regulators focus more attention on the management...more

Jenner & Block

Client Alert: The Proliferation of Plastics Litigation and Insurance Coverage

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Concerns surrounding plastic, particularly microplastics and synthetic microfiber, pollution are growing. As federal and state governments continue to focus on this issue, lawsuits seeking to hold companies accountable for...more

Verrill

Better Communication Among Regulators and the Regulated Can Improve Outcomes for Wastewater Permittees

Verrill on

As our understanding of the environment and anthropogenic impact grows, protection efforts increasingly spawn regulation. Media coverage of perceived harms to health and the environment and well-funded advocacy by...more

Nossaman LLP

EPA Takes Next Step in PFAS Regulations – Proposing Adding Nine PFAS as Hazardous Constituents

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On January 31, 2024, the U.S. Environmental Protection Agency (EPA) announced that it is proposing to list nine per- and polyfluoroalkyl substances (PFAS) as hazardous constituents under the Resource Conservation and Recovery...more

Nossaman LLP

Ninth Circuit Issues Decision Upholding its Interpretation of “Discharged” for Clean Water Act NPDES Violations

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On November 20, 2023, a panel of the Ninth Circuit Court of Appeals issued its opinion in Idaho Conservation League v. Poe, No. 22-35978. Therein, the Court upheld its previous interpretation of “discharged” in the context of...more

Nossaman LLP

Ninth Circuit Issues Clean Water Act Opinion Addressing Indirect vs. Direct Discharge and Notice Requirements

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On November 21, 2023, the Ninth Circuit Court of Appeals issued its decision in Cottonwood Environmental Law Center vs. Edwards addressing various Clean Water Act issues. Its two key holdings were that (1) the district court...more

Brownstein Hyatt Farber Schreck

EPA Delays PFAS CERCLA Designation, Other PFAS Regulatory Efforts on Schedule

The Environmental Protection Agency’s (EPA) Spring 2023 Unified Agenda, released on June 13, 2023, extends EPA’s estimated publication of a final rule designating certain per- and polyfluoroalkyl substances (PFAS)—namely...more

BCLP

PFAS Update: Proposed New Legislation Intended to Exempt Certain Industries from PFAS Liability

BCLP on

On May 3, 2023, Cynthia Lummis (R-WY) introduced five bills in the U.S. Senate proposing several PFAS liability exemptions to the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (“CERCLA”)....more

Williams Mullen

Liability for Invalid State Agency Permit Decisions: Is the Regulated Party Left Holding the Bag?

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Regulated parties who comply with their permit sometimes get an unwelcome surprise. They meet with their state agency, make full disclosure about their discharges or emissions, and then the state agency makes decisions about...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Wastewater Enforcement: Arkansas Department of Energy and Environment - Division of Environmental Quality and City of Keo Enter...

The Arkansas Department of Energy and Environment – Division of Environmental Quality (“DEQ”) and the City of Keo, Arkansas, (“Keo”) entered into a February 10th Consent Administrative Order (“CAO”) addressing an alleged...more

Williams Mullen

Minimizing Storm-Related Environmental Liability

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For many facilities and construction sites, the routine practical problems arising from wet weather go with the territory. However, if stormwater management is compromised or if flooding and coastal storm surges occur, a...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Low Flow Statistics Tools: U.S. Environmental Protection Agency Issues October 2018 Input for NPDES Permit Writers

The United States Environmental Protection Agency (“EPA”) issued an October 2018 publication titled: Low Flow Statistics Tools – A How-To Handbook for NPDES Permit Writers (“Handbook”) - See EPA-833-B-18-001. EPA...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Does a Discharge to Groundwater Require an NPDES Permit?: Jordan Wimpy (Mitchell Williams) Arkansas Environmental Federation...

My law firm colleague Jordan Wimpy undertook a presentation at the October 4th Arkansas Environmental Federation Annual Conference titled: Does a Discharge to Groundwater Require an NPDES Permit? (“Presentation”)...more

Clark Hill PLC

Clean Water Act Groundwater Pollution Liability in Limbo

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The Clean Water Act (CWA) is facing an identity crisis. In the past year, conflicting federal court decisions have created a circuit split as to whether the CWA regulates pollutant releases into groundwater that is...more

WilmerHale

Sixth Circuit Holds Clean Water Act Does Not Require Permits for Discharges to Groundwater

WilmerHale on

On September 24, 2018, the US Court of Appeals for the Sixth Circuit ruled that the Clean Water Act (CWA) does not require a National Pollution Discharge Elimination System (NPDES) permit for the discharges of pollutants to...more

Bricker Graydon LLP

Sixth Circuit rules that the Clean Water Act does not regulate discharges to navigable waters via groundwater

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In two opinions issued on September 24, 2018, the Sixth Circuit ruled that discharges of a pollutant to surface waters through groundwater do not require a National Pollutant Discharge Elimination System permit, pursuant to...more

Best Best & Krieger LLP

[WEBINAR] Fairly (or Unfairly?) Traceable: Are Discharges Through Groundwater Subject to the Clean Water Act?

A recent decision by the U.S. Ninth Circuit Court of Appeals (Hawai'i Wildlife Fund v. County of Maui) created a new standard for permitting under the Clean Water Act — one that captures discharges from point sources through...more

Farella Braun + Martel LLP

Fourth Circuit Joins Ninth Circuit in Expanding Clean Water Act Jurisdiction Over Discharges to Navigable Waters Conveyed Through...

Unpermitted point source discharges that reach navigable waters indirectly, via groundwater, may lead to Clean Water Act (CWA) liability according to the Fourth Circuit Court of Appeals (encompassing Maryland, Virginia, North...more

Perkins Coie

Clean Water Act Permit May Be Required for Pollution Discharged Indirectly into Navigable Waters

Perkins Coie on

A Clean Water Act permit is required for discharging wastewater from injection wells into groundwater where wastewater is “fairly traceable” to navigable waters, the U.S. Court of Appeals for the Ninth Circuit held in Hawai’i...more

Burr & Forman

EPA Seeks Comments on Discharges of Pollutants to Groundwater

Burr & Forman on

On February 20, the Environmental Protection Agency published in the Federal Register a request for comments on a longstanding EPA policy regarding the question of whether and to what extent discharges to groundwater might be...more

King & Spalding

As Ninth Circuit Expands Clean Water Act Liability for Groundwater Discharges, EPA Seeks Comment on Clean Water Act Coverage

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A recent Ninth Circuit decision has expanded Clean Water Act (“CWA” or the “Act”) liability, holding that discharges to groundwater are actionable if there is a “fairly traceable” connection between the groundwater discharge...more

Farella Braun + Martel LLP

Ninth Circuit Ruling Expands Clean Water Act Jurisdiction Over Groundwater Discharges

A recent ruling by the Ninth Circuit Court of Appeals, which covers California, Oregon and several other western states, potentially extends Clean Water Act (CWA) jurisdiction to require permits for point source discharges...more

Brownstein Hyatt Farber Schreck

Ninth Circuit Holds Wastewater Discharge to Groundwater Requires Clean Water Act Permit in Hawai’i Wildlife Fund v. County of Maui

On Feb. 1, 2018, the U.S. Court of Appeals for the Ninth Circuit issued a highly anticipated decision in Hawai’i Wildlife Fund v. County of Maui, No. 15-17447 (9th Cir. Feb. 1, 2018). At issue was whether the County of Maui...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Identifying and Addressing Environmental Issues in Petroleum Marketing Agreements (“Presentation”)

The Arkansas Oil Marketers Association Environmental Workshop was held on August 30th in Little Rock. I undertook a presentation titled: Identifying and Addressing Environmental Issues in Petroleum Marketing...more

Carlton Fields

DOAH Strikes Proposed Rule Requiring Public Notification of "Reportable Releases"

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On December 30, the Division of Administrative Hearings (DOAH) entered a final order invalidating the Department of Environmental Protection’s (DEP) proposed rule expanding notification requirements for every release of any...more

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