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Clean Air Act
Whether it’s negotiating consent decrees, preparing and reviewing Title V applications and permitting, or counseling on pollution control strategies including emissions trading credits, we have the knowledge you need. Squire Sanders lawyers have extensive experience in counseling clients in matters related to the Clean Air Act including defending federal court enforcement actions; counseling and negotiating with agencies on permits, variances, and state implementation plan revisions; representing clients in administrative rulemaking; challenging regulations in court; and providing assistance in responding to agency information requests.
More specific examples of work done on behalf of clients include:
- Representing a steel manufacturer nationwide in renegotiating multiple consent decrees under a special Act of Congress.
- Preparing and reviewing Title V applications and permitting for Fortune 500 and smaller companies involved in numerous industries, including steel, pulp and paper, chemicals and coatings.
- Counseling a Fortune 500 company with plants in Ohio, Pennsylvania and Nevada regarding an alternative plant-wide (bubble) air pollution control strategy involving the trading of emission reduction credits from over control of some lines to offset higher emissions from other lines.
- Negotiating the first national “stretch-out” order on behalf of a steel corporation which order was incorporated into nine federal district court consent decrees in five EPA regions.
- Negotiating a model consent decree involving EPA’s first “stop construction order” under section 113(a)(5) of the Clean Air Act added by the 1990 Amendments, thereby allowing the client to proceed with a US$500 million modernization program.
- Negotiating at the federal and state level the development and implementation of Title V rules and permits under the 1990 Clean Air Act Amendments.
- Counseling in cases establishing precedents for pre-enforcement judicial review of section 113 Notices of Violation.
- Advising in a consolidated challenge to federal air regulations governing “prevention of significant determination.”
- Successfully challenging an EPA attempt to regulate engine oil additives, and related jurisdictional issues.
- Challenging federal SO2 rules resulting in post-argument revision by EPA of client’s emission limitations.
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