Tag: epa


WOTUS Rule: Permitting Changes Set Up Busy Spring

On February 14, 2018, the US Army Corps of Engineers (USACE) and U.S. EPA  published the latest installment in the Waters of the U.S. (WOTUS) groundhog day saga.  Promising regulatory certainty, the rule is notable for how similar it is to the 1986/1988 WOTUS definition.  However, many in the regulated community will note that the […]


Ongoing Fallout: WOTUS Litigation Pose Hurdles For Permit Applicants

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In August of this year, the U.S. District Court of South Carolina halted a federal moratorium on the 2015 Obama era WOTUS rule for 22 states.  As a result, two different federal definitions are being applied in states across the country as to what constitutes a “water of the US”.  Naturally this is problematic for […]


BUILD Act: Changes to the CERCLA Bona Fide Prospective Purchaser Liability Defense

The 2018 Brownfields Utilization, Investment, and Local Development (BUILD) Act was enacted by the United States Congress on March 23, 2018 as part of the Consolidated Appropriations Act of 2018.  The BUILD Act ( page 705 of the Appropriations Act) more than doubles funding for the EPA Brownfield Program, authorizing the appropriation of up to […]


Labelling Hazardous Waste Containers - KY adopts GIR

The Kentucky Division of Waste Management has adopted revisions to the Resource Conservation and Recovery Act (RCRA) regulations that became effective on December 7, 2017.  These revisions affect labelling of hazardous waste containers for Small Quantity Generators (SQG), Large Quantity Generators (LQG), transporters, and Treatment, Storage and Disposal Facilities (TSDF). For SQGs and LQGs, containers […]


EPA Seeks Input on Regulations for Repeal

On April 13, 2017 the EPA published a request in the Federal Register “seeking input on regulations that may be appropriate for repeal, replacement, or modification”. This request is EPA’s response to Executive Order 13777. This request for comment by the EPA is in keeping with a broad listening session the new Administration is doing […]

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