By Jeryl L. Olson, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis:  EPA, in an Advance Notice of Proposed Rulemaking, requests comments on adding certain per- and polyfluoroalkyl substances (PFAS) to the TRI chemical list.

The U.S. Environmental Protection Agency (EPA) has asked industry stakeholders to provide comments on a proposal

By Jeryl L. Olson and Andrew H. Perellis

Seyfarth Synopsis: USEPA published an Interpretive Statement (dated April 12, 2019), which according to the Agency “clarifies” that releases of pollutants to groundwater from a point source are “categorically excluded” from Clean Water Act National Pollutant Discharge Elimination System (NPDES) permitting requirements. 

According to the Agency,

By Jeryl L. OlsonKay R. Bonza, and Craig B. Simonsen

Seyfarth Synopsis:  In a guidance document issued last week, U.S. EPA sets out to deliberately move environmental enforcement responsibilities back to the states. While this may, to local interests, represent a noble purpose, few states are manned and ready to take

By Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen

Seyfarth Synopsis: EPA has promulgated its new per violation penalty rules for 2018.

The U.S. Environmental Protection Agency (EPA) has again issued final regulations adjusting the maximum civil penalty dollar amounts for violations of various environmental regulations. 83 Fed. Reg. 1190

By Andrew H. Perellis, Kay R. Bonza, and Craig B. Simonsen

EPA SignSeyfarth Synopsis: The EPA and Army Corps of Engineers have proposed to rescind the 2015 Clean Water Rule defining “Waters of the U.S.,” and recodify the pre-existing rule, then engage in a subsequent rulemaking to re-evaluate and revise the definition of

By Andrew H. Perellis, Kay R. Bonza, and Patrick D. Joyce

Seyfarth Synopsis: With a dramatic change from a progressive democratic to a conservative republican administration, we anticipate that EPA is not only likely to pivot away from an enforcement heavy to a more business friendly agenda, it is also likely to

By Kay R. Bonza and Craig B. Simonsen

Private jet plane in the blue skySynopsis: EPA’s recent finding paves the way for the Agency to develop standards regulating greenhouse gas emissions from aircraft. Businesses in the commercial jet manufacturing and aviation transportation industry should watch this rulemaking closely, as it will affect environmental compliance costs and may have an impact on

By Andrew H. Perellis, Patrick D. Joyce, and Craig B. Simonsen

Compliance Concept on İnterface Touch ScreenSeyfarth Synopsis: EPA finalized its new per violation penalty rules that in some cases now increase by substantial amounts.

In a federal rulemaking published last week, the U.S. Environmental Protection Agency (EPA) issued interim final regulations adjusting the maximum civil penalty