White Paper

7 Pages
  • 7 Pages

U.S. EPA’s Reversal on “Once In Always In” Policy Opens Door to Reduced Clean Air Act Obligations


Is "once in always in" out?

Earlier this year the US EPA Office of Air and Radiation’s assistant administrator published a memorandum to all regional air division directors that pulled the plug on the historic “Once In Always In” policy for major sources under the NESHAP program. This white paper provides background to this original policy, the new policy and its implications and potential drawbacks.



Lianne Mantione

Squire Patton Boggs

Lianne Mantione is a principal at Squire Patton Boggs. Her practice includes all aspects of environmental law with particular emphasis on litigation of complex environmental matters and counseling clients on regulatory compliance, risk management and enforcement defense.

She has defended clients against federal and state toxic tort and mass tort actions (including class action cases), defended clients in federal and state agency enforcement actions, and represented clients in multiple federal and state administrative appeals. Lianne also regularly counsels clients on developing compliance and risk management strategies for state and federal permitting and reporting requirements under the Clean Air Act.

John D. Lazzaretti

Squire Patton Boggs

John Lazzaretti is a principal at Squire Patton Boggs. He focuses his practice on environmental law, with an emphasis on complex environmental litigation and rulemaking appeals.

John’s experience includes defending industrial and municipal clients against federal, state and private enforcement actions arising under the Clean Water Act, Clean Air Act, Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), Resource Conservation and Recovery Act (RCRA) and common law claims. John has represented clients in challenges to regulatory actions under the Clean Air Act, Clean Water Act and their state counterparts in courts across the country.

All of your training, right here at Lorman.

Pay once and get a full year of unlimited training in any format, any time!

  • Live Webinars
  • OnDemand Webinars
  • MP3 Downloads
  • Course Manuals
  • Audio Recordings*
  • Executive Reports
  • White Papers and Articles
  • Sponsored Live Webinars

Additional benefits include:

  • State Specific Credit Tracker
  • Members Only Newsletter
  • All-Access Pass Course Concierge

* For audio recordings you only pay shipping

Questions? Call 877-296-2169 to speak with a real person.

Sign Up Today

Access to all training products $699/year

Unlimited Lorman Training

With the All-Access Pass there is no guessing what you will need for your yearly training budget. $699 will cover all of your training needs for an entire year!

Easy Registrations

Once you purchase your All-Access Pass you will never be any further than one-click away from attending any Lorman training course.

Invest in Yourself

You haven't gotten to where you are professionally by luck alone; it's taken a lot of hard work and training. Invest in yourself with the All-Access Pass.