News & Analysis as of

Proposed Rules Clean Air Act National Emissions Standards

Williams Mullen

EPA Proposes Removing Affirmative Defense Provisions from Eighteen Clean Air Act Emission Standards

Williams Mullen on

In a proposed rule published on June 24, 2024, EPA has proposed to remove eighteen affirmative defense provisions for malfunctions associated with violations of New Source Performance Standards (NSPS) and National Emission...more

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

Project Emissions Counting/Clean Air Act: Waste-to-Energy Association Comments on U.S. Environmental Protection Agency's Proposed...

The Waste-to-Energy Association  (“WTEA”) submitted July 1st comments to the United States Environmental Protection Agency (“EPA”) addressing the proposed rule styled: Prevention of Significant Deterioration (PSD) and...more

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

New Source Performance Standards/National Emission Standards for Hazardous Air Pollutants: U.S. Environmental Protection Agency...

The United States Environmental Protection Agency (“EPA”) issued a pre-publication version of a proposed rule that would remove affirmative defense provisions from certain Clean Air Act New Source Performance Standards...more

Jones Day

EPA Proposes Regulations to Implement Methane Fee

Jones Day on

The U.S. Environmental Protection Agency ("EPA") has proposed regulations for calculating methane emissions fees required beginning this year under the Inflation Reduction Act ("IRA"). Section 136 of the Clean Air Act (added...more

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

Hazardous Air Pollutants/Clean Air Act: U.S. Environmental Protection Agency Proposed Rule Addressing Issues Associated with...

The United States Environmental Protection Agency (“EPA”) published in the September 13th Federal Register a proposed rule that would amend the general provisions for Clean Air Act National Emission Standards for Hazardous...more

Jenner & Block

New EPA Rule Removes Emergency Defense Waiver in Title V Air Permits

Jenner & Block on

On July 21, 2023, the Environmental Protection Agency published a final rule eliminating an affirmative defense for Clean Air Act permit emissions violations caused by “emergency” circumstances. “Major sources” (i.e....more

Hogan Lovells

EPA’s proposes most stringent vehicle emission standards ever for model years 2027-2032

Hogan Lovells on

On April 12, 2023, the Environmental Protection Agency (EPA) issued the notice of proposed rulemaking for “Multi-Pollutant Emission Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles” (the “proposed...more

Goldberg Segalla

Highly Anticipated Proposed EtO Rules the EPA Just Announced: Were They Worth The Wait?

Goldberg Segalla on

After years of delays – largely due to the COVID-19 pandemic – on April 11, 2023, the U.S. Environmental Protection Agency finally issued two proposals that would reduce ethylene oxide (EtO) emissions affecting fence-line...more

Williams Mullen

EPA Proposed Rule: Fugitive Emissions Count Toward PSD Significant Emissions Increase Thresholds

Williams Mullen on

EPA is proposing revisions to the new source review (“NSR”) permit program (“2022 Proposed Fugitive Emissions Rule”) under the federal Clean Air Act (“CAA”), which will codify the requirement that modifications account for...more

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

Miscellaneous Coating Manufacturing/NESHAP: U.S. Environmental Protection Agency Proposed Residual Risk and Technology Review

The United States Environmental Protection Agency (“EPA”) published a September 4th Federal Register Notice proposing the results of a Residual Risk and Technology Review (“RTR”) of the Clean Air Act National Emission...more

Williams Mullen

States Push Back on EPA's Position on Landfill Emissions

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Last year, we reported on EPA’s decision to allow the expiration of a moratorium on the 2016 Obama Climate Action Plan rule and guidelines seeking to reduce landfill methane emissions (“Methane Rule and Guidelines”)....more

Foley & Lardner LLP

Oilfield Operators Take Note: EPA is Poised to Relax Your Vapor Monitoring Deadlines and Streamline Your Bureaucratic Layers

Foley & Lardner LLP on

Oilfield operators of every size have been busy implementing the Obama Administration’s labor-intensive requirements to detect and repair vapor leaks from well site equipment, often called the Quad Oa requirements, in...more

Jones Day

EPA Memo Signals Plant Improvement Opportunities

Jones Day on

A policy memorandum issued by the U.S. Environmental Protection Agency (“EPA”) during December 2017 clarifies how the agency will apply and enforce certain facets of the New Source Review regulations following a pair of...more

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