By Eric Hiser In our article on “A New Beginning for ‘Begin Actual Constriction’ ” in September 2025, we discussed the EPA’s guidance in an individual source letter that relaxed the historic policy interpretation of “begin actual construction.” Readers may recall that historically, EPA has taken the position that any […]
Category: News
SPRingBoard Environmental Law Podcast Episode 7: “Brownfield Remediation in New York State: Key Regulatory Changes and Implications for Developers” https://open.spotify.com/episode/0EG12P5HJR4KG4We7ZPahS?si=BEMBXVdMS0iY3p3Uiylnog This special episode of SPRingBoard was recorded as part of a joint webinar hosted by Sive, Paget & Riesel P.C. and Bousquet Holstein PLLC. ERevised regulations for New York’s environmental remediation […]
Recent Federal DevelopmentsMarch 16, 2026“TSCA CBI Re-substantiation: When, Why, and How to Prepare,” April 9, 2026, 11:00 a.m. – 12:00 p.m. (EDT), via webinar The Toxic Substances Control Act (TSCA) provides critical protections for commercially sensitive information related to a company’s business, processes, and chemicals. The 2016 Frank R. Lautenberg […]
Mar 16, 2026
Comments on Minnesota’s Draft Concepts for a CUU Rule Are Due March 29, 2026 – Update from Bergeson & Campbell, P.C.
The Minnesota Pollution Control Agency (MPCA) held a webinar on February 26, 2026, on its currently unavoidable use (CUU) rule concepts. Under Minnesota’s per- and polyfluoroalkyl substances (PFAS) statute, beginning January 1, 2032, intentionally added PFAS in almost all products will be prohibited in Minnesota unless MPCA issues a CUU determination for […]
March 12, 2026 As predicted in our forecast article, EPA proposed to revise its Risk Management Program (RMP), applicable to facilities that handle “extremely hazardous substances.” The proposal, referred to as the Common Sense Approach to Chemical Accident Prevention, intends to undo many provisions finalized in the Biden Administration’s former Safer Communities […]