Fri Apr 17th, On Rulemaking and Legislative Practice, by Kimberly Bick
If you live in California, you may have noticed the steep decline in prices at the pump. You can thank the U.S. EPA for that. Every spring, gas prices seem to skyrocket. The difference between summer- and winter-grade gasoline involves the Reid Vapor Pressure (RVP) of the fuel. RVP is a measure of how easily the fuel evaporates at a given temperature. The more volatile a gasoline (higher RVP), the […]
Wed Apr 15th, On Rulemaking and Legislative Practice, by Kimberly Bick
The U.S. Department of Interior recently argued that, prior to the Trump Administration, the Migratory Bird Treaty Act (“MBTA”), 16 U.S.C. § 703(a), had been improperly enforced. According to the Department of Interior, the Act’s original intent was to criminalize the intentional killing of protected birds. Opponents to the Department of Interior’s interpretation have argued that the Act applies strict liability, such that accidental killing or injuring migratory birds resulting […]
Fri Apr 10th, On Compliance Counseling, by Kimberly Bick
Today, EPA issued its “Interim Guidance on Site Field Work Decisions Due to Impacts of COVID-19.” This guidance provides important information for regulated entities, consultants, EPA’s partners, and the public concerning response actions at Superfund and RCRA sites. It is a follow-up to EPA’s previous Memorandum on March 27, “COVID-19 Implications for EPA’s Enforcement and Compliance Assurance Program,” which did not cover CERCLA and RCRA response actions and enforcement actions, […]
Wed Apr 8th, On Compliance Counseling, by Kimberly Bick
As defined by the federal government, the food supply, including all food facilities and the agriculture industry, makes up critical infrastructure from farm to table and includes assets, systems, networks, and functions that provide vital services to the nation. It is essential that the food supply and associated supply chains are protected, and remain operational, including a workforce that is vital to production of the food supply. Promoting the ability […]
