Strategic Civil-Criminal Enforcement Policy: U.S. Environmental Protection Agency April 17th Memorandum
The United States Environmental Protection Agency (“EPA”) issued an April 17th memorandum addressing: Strategic Civil-Criminal Enforcement Policy (“Memorandum”) The Memorandum was transmitted from EPA Administrator for Enforcement and Compliance Assurance David M. Uhlmann to the following agency…
Air Enforcement: Missouri Department of Natural Resources and Hartville Power Generation Facility Enter into Administrative Order on Consent
The Missouri Department of Natural Resources (“MDNR”) and Black Oak Power Producers, LLC (“Black Oak”) entered into an April 8th Administrative Order on Consent (“AOC”) addressing an alleged violation of a Part 70 (Title V) air permit and Missouri Air Regulation. See No. APCP-2023-028. The AOC…
Air Enforcement: Arkansas Department of Energy & Environment - Division of Environmental Quality and Fort Smith Silica Product Manufacturer Enter into Consent Administrative Order
The Arkansas Department of Energy & Environment – Division of Environmental Quality (“DEQ”) and Covia ISP, Inc. (“Covia”) entered into an April 15th Consent Administrative Order (“CAO”) addressing an alleged violation of an air permit. See LIS No. 24-068. The CAO provides that Covia owns and…
Arkansas Recycling Tax Credit: Arkansas Department of Energy and Environment - Division of Environmental Quality Update
The Arkansas Recycling Equipment Tax Credit Program was created by Act 654 of 1993. The program encourages recycling by allowing Arkansas taxpayers a 30 percent state income tax credit for the purchase of equipment used exclusively for collecting, separating, processing, modifying, converting, or…
PFAS/CERCLA: U.S. Environmental Protection Agency Enforcement Discretion and Settlement Policy
Simultaneously with the prepublication of a final rule designating two of the Per- and Polyfluoroalkyl substances (“PFAS”) as Comprehensive Environmental Response, Compensation and Liability Act (“CERCLA”) hazardous substances, EPA issued an April 19th memorandum titled: PFAS Enforcement Discretion…