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.

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

Agenda

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

Faculty

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.

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

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