On September 17, 2014, EPA further revised its policy regarding start-up, shut-down, and malfunction (SSM) events, issuing a Supplemental Notice of Proposed Rulemaking (SNPR) that would remove the availability of an affirmative defense for air emission exceedances resulting from malfunction events.
Laura Granier has joined Davis Graham & Stubbs LLP as a partner in the firm’s Natural Resources Department. Ms. Granier will be based out of Reno, where she will lead the firm’s new Nevada office. Her practice will focus on mining issues in that state as well as complex commercial litigation, regulatory work, and government affairs.
On October 6, 2014, EPA issued a final rule updating its All Appropriate Inquiries (AAI) Rule to remove the previous reference to the outdated 2005 ASTM International (ASTM) Standard Practice for Phase I Environmental Site Assessments and replace it with a sole reference to the 2013 Standard, ASTM E1527-13.