The Energy Law Blog
DECEMBER 27, 2023
This 2015 SIP Call rule focused on the treatment of excess emissions during periods of startup, shutdown, or malfunction (SSM). K Startup and Shutdown, in its place. Essentially, EPA noted that Louisiana’s rules “may be read so as to create situations wherein startup and shutdown emissions are functionally exempt[.]” LAC 33:III.2201.K
The Energy Law Blog
JANUARY 16, 2019
US Government Shutdown Although the US government, and the SEC, is shutdown, advisers should continue to meet all statutory and regulatory deadlines as set forth in the SEC’s Operations Plan Under Government Shutdown (Dec. 51:703(D)(5). The forms are available from the Commissioner of Securities office.
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The Energy Law Blog
MARCH 27, 2020
With shutdowns and stay-at-home orders in place and regulatory deadlines looming, Louisiana operators are looking for guidance from regulators on how to proceed. The impacts of COVID-19 have rapidly swept across the country and the globe. Failure to timely submit reports could result in a Compliance Order with a civil penalty.
The Energy Law Blog
MARCH 1, 2021
One article estimates that approximately 100,000 businesses have permanently closed and another article states that more than 57 million people have filed for unemployment since the crisis began. These numbers are hellacious, and the impact of the crisis is not over. Again- having a well thought out strategy is essential before filing.
The Energy Law Blog
JUNE 2, 2020
Amidst historically low oil prices and economic shutdowns, fossil fuel companies continue to defend against lawsuits brought by state and local governments claiming climate-change related damages. 1442(a)(1). In City of Oakland et al. 1442(a)(1). 1442(a)(1).
The Energy Law Blog
MARCH 1, 2021
One article estimates that approximately 100,000 businesses have permanently closed and another article states that more than 57 million people have filed for unemployment since the crisis began. These numbers are hellacious, and the impact of the crisis is not over. Again- having a well thought out strategy is essential before filing.
The Energy Law Blog
OCTOBER 14, 2021
On September 30, 2021, the EPA once again signaled a policy change on what provisions a state can include in its Clean Air Act State Implementation Plan (“SIP”) for exemptions and affirmative defenses during periods of startup, shutdown, and malfunction (“SSM”). 2015 SSM SIP Policy. 33840 (June 12, 2015). LAC 33:III.507.J.1.
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