Rule Development

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Our lawyers have participated in virtually all major rulemakings surrounding the implementation of the Clean Air Act as well as recent EPA initiatives to regulate interstate pollutants, mercury emissions and greenhouse gases. Our air team regularly assists clients throughout the promulgation process, including developing comments on proposed regulations and testimony for public hearings and arranging meetings with state and federal agencies to address company-specific issues. These engagements often influence final rules and form the basis for future legal challenges and appeals.

The firm’s practice is experienced in advising clients on various technical and legal aspects of Clean Air Act regulations, including:

  • Maximum achievable control technology standards (MACT) for hazardous air pollutants for several industries, including cement kilns and electric generating units
  • National Ambient Air Quality Standards (NAAQS) for stationary sources
  • Cross-State Air Pollution Rule (CSAPR) for electric generating units
  • New and existing source performance standards for greenhouse gas emissions for electric generating units