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Jacob Hollinger handles environmental and energy-related compliance and litigation matters for energy, manufacturing and financial sector clients. He is a former high-ranking Clean Air Act attorney for the US Environmental Protection Agency (EPA), has handled dozens of government investigations and enforcement actions and has extensive experience in all aspects of civil litigation. Read Jacob Hollinger's full bio.

An Update on EPA’s Approach to Methane Emissions from the Oil & Gas Sector – Including a Summary of the Agency’s Proposed New Reporting Rule


By on Dec 4, 2014
Posted In Environmental

The U.S. Environmental Protection Agency (EPA) is expected to announce between now and December 31, 2014 its plan for pursuing methane reductions from the oil and gas sector – including whether it will propose new emission reduction regulations.  Additionally, the agency recently modified its greenhouse gas (GHG) reporting rules for oil and gas systems and...

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EPA Proposes to Eliminate Affirmative Defenses for Many Clean Air Act Violations


By and on Sep 16, 2014
Posted In Environmental

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on September 5, 2014 that would prevent states from including affirmative defenses in their Clean Air Act state implementation plans (SIPs) for emissions exceedances that occur during startup, shutdown and malfunction (SSM) periods.  The proposal would also require several states to revise their existing SIPs...

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The Supreme Court’s Greenhouse Gas Permitting Decision – What Does It Mean?


By on Jun 23, 2014
Posted In Environmental

The U.S. Supreme Court today partly upheld and partly rejected the U.S. Environmental Protection Agency’s federal Clean Air Act permitting regulations governing greenhouse gas (GHG) emissions from stationary sources.  The decision is mostly a victory for EPA, and its narrow scope means that it will almost certainly not disrupt, let alone invalidate, EPA’s ongoing Section...

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The Third Piece of EPA’s Clean Power Plan: GHG Emission Limits for Modified and Reconstructed Power Plants


By and on Jun 16, 2014
Posted In Uncategorized

The U.S. Environmental Protection Agency’s proposed greenhouse gas (GHG) regulations for “new” and “existing” power plants have received substantial media attention, but regulated parties should also be aware of the third piece of EPA’s self-styled “Clean Power Plan”:  Proposed carbon dioxide (CO2) emission limits for “modified” and “reconstructed” electricity generating units (EGUs). EPA proposed CO2...

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EPA’s Proposed Power Plant Regulations – Simpler Than You Think


By on Jun 4, 2014
Posted In Environmental

The U.S. Environmental Protection Agency (EPA) released its long-anticipated proposal for regulating greenhouse gas emissions from existing power plants on June 2, 2014, to much fanfare.  The proposal is simpler than it looks.  Here are the key points. 1.  The Proposed Rule is Only 38 Pages Long.  It’s the “Justification” That Takes up Space.  Many...

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EPA’s Next Generation Compliance Initiative – The Agency’s Latest Proposed Rule for Refineries Shows the Initiative in Action and Provides a Glimpse of the Future for Other Industries


By on May 27, 2014
Posted In Environmental

The U.S. Environmental Protection Agency (EPA) recently released a proposed rule that illustrates several of the agency’s Next Generation Compliance ideas in action.  The proposed rule concerns hazardous air pollutant (HAP) emissions from refineries, but should be studied by anyone who wants to gain a better understanding of what “Next Generation Compliance” means as a...

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Wind Farms and Eagle “Take” Permits – Litigation is Coming Over the New “30-Year” Permit Rule


By on May 5, 2014
Posted In Environmental, Project Development and Finance, Renewables

The U.S. Fish and Wildlife Service (FWS) recently changed its eagle “take” permitting rules to allow wind developers to apply for 30-year take permits; previously, such permits, which allow the incidental killing of eagles, were available for a maximum of just five years.  Wind developers had lobbied for the rule change based on concerns that...

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CSAPR Reinstated, But Some Upwind States May Be Able to Bring As-Applied Challenges


By on Apr 29, 2014
Posted In Environmental

The U.S. Supreme Court today upheld the U.S. Environmental Protection Agency’s Cross State Air Pollution Rule, otherwise known as CSAPR or the “Transport Rule,” reversing a lower court decision that had vacated that rule.  The decision means that large sources of nitrogen oxide and sulfur dioxide emissions in upwind states – especially coal-fired power plants...

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The President’s Methane Reduction Strategy – Here’s What Energy Companies Need to Know


By and on Apr 17, 2014
Posted In Environmental, Natural Gas

President Obama recently released a Strategy to Reduce Methane Emissions (Strategy) that sets forth a multi-pronged plan for reducing methane emissions both domestically and globally.  Domestically, the plan is to focus on four sources of methane—the oil and gas sector, coal mines, agriculture and landfills—and to pursue a mix of regulatory actions with respect to...

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Deadline Extended to Submit Comments on EPA’s Proposed Greenhouse Gas Emission Limits for New Power Plants


By on Feb 27, 2014
Posted In Environmental

The U.S. Environmental Protection Agency (EPA) has announced that it is extending until May 9, 2014, the deadline for submitting comments on its proposed rule to set greenhouse gas emission limits for new coal- and gas-fired power plants.  The announcement came in a Federal Register notice signed by EPA on February 26 and slated for...

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