EPA Reverses Obama-Era Interpretation of New Source Review Major Source Trigger
Are huge facilities not subject to the constraints of the major clean air new source review?
The US EPA released a recent memorandum which illustrates a considerable change in the current translation of the new source review rules in regards to prospective projects prompting NSR requirements. This white paper provides background to and implications of this memorandum.
Jeffrey N. Hurwitz is of counsel with Morgan, Lewis & Bockius LLP. He focuses on environmental matters involving clean air, hazardous and solid waste issues, clean water, chemical and pesticide regulation, storage tanks, environmental audits, corporate transactions, and Superfund. Jeffrey defends clients in US Environmental Protection Agency (EPA) and state environmental civil and criminal enforcement actions. He also represents clients before the EPA’s Office of Chemical Safety and Pollution Prevention on chemical and pesticide regulation matters, particularly the premanufacture notice process under the Toxic Substances Control Act.
Rick R. Rothman
Morgan, Lewis & Bockius LLP
Rick R. Rothman is a partner with Morgan, Lewis & Bockius LLP. He focuses on environmental and energy counseling and litigation. Rick’s practice encompasses a broad range of environmental and energy laws, including the laws and regulations concerning air quality (both stationary and mobile sources), water quality, power plant siting, hazardous substances, impacted properties, energy efficiency, climate change, and Proposition 65. He is recognized for his environmental work by Chambers USA, where clients describe Rick as an “expert in air quality matters” and “very smart and knowledgeable, and easy to work with.”
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