May 6, 2026

EPA “Begin Actual Construction” rule imminent – Update from Hiser Burggraff Curtis

Posted by Eric Hiser

The Office of Management and Budget (OMB) has completed its review of the EPA’s proposed rule that will address changes to the existing definition of “begin actual construction” according to an announcement on the OMB website. This means that the proposed rule should appear in the Federal Register in the near future. The new rule is anticipated to follow the lead of EPA’s letter issued to the Maricopa County Air Quality Department. You can read about that guidance letter in NSR Law Blog’s…

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