Home / Month: June 2018
28 Jun 2018Preparing for PFAS Regulation – Important Considerations on Emerging Contaminants
I just gave a presentation on emerging contaminants, with the response to “PFAS” contamination – perfluorinated chemicals – the latest, high-profile set of chemicals providing lessons for the regulated community (and perhaps regulators) to learn from. This presentation was an outgrowth of a State Bar journal article I’d recently published providing a primer on how
19 Jun 2018More Challenges to WOTUS Rule, More States Under Court-Ordered Stays
Challenges of the U.S. EPA’s 2015 Waters of the United States (WOTUS) rule are nothing new. However, a recent district court decision highlights the complexities created by current and expected lawsuits related to the Trump Administration’s efforts to repeal and replace the WOTUS rule. The Obama U.S. EPA’s 2015 promulgation of the WOTUS rule led
12 Jun 2018Appeals Court Recycles RCRA Recycling Exclusions
On May 30, 2018, U.S. EPA published revised Resource Conservation and Recovery Act (RCRA) requirements governing hazardous waste generators. These revised requirements implement a mandate by the U.S. Court of Appeals for the District of Columbia. The court’s decision was based on consideration of revisions U.S. EPA had proposed to the RCRA rules in 2015.
01 Jun 2018U.S. EPA Asks for Help Developing Blending Rule for POTWs – This Time, Do They Mean It?
U.S. EPA recently announced its intent to develop a proposed rulemaking to govern the use of blending to treat peak wet weather flows at public wastewater utilities. This isn’t the first time, the agency has started this process, but Administrator Pruitt’s comments suggest the effort may go the distance this time. U.S. EPA has long recognized