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A series of recent actions undertaken by President Biden, near the end of his term, and President Trump, in the early days of his presidency, have called into question a key issue under the Outer Continental Shelf Lands Act (“OCSLA”) — whether the President can revoke a previous President’s withdrawal of areas of the United States Outer Continental Shelf (“OCS”) from oil and gas leasing.

On February 8, 2024, the Environmental Protection Agency (EPA) published two proposed rules that would expand its regulatory authority over PFAS: one to list nine PFAS as hazardous constituents subject to the Resource Conservation and Recovery Act (“RCRA”) corrective action program (the “PFAS Constituent Rule”) and another to expand the regulatory definition of RCRA hazardous waste to address PFAS releases from RCRA-permitted solid waste management units (the “Definition Rule”).

At long last, the U.S. Environmental Protection Agency (“EPA”) is poised to grant Louisiana authority to issue Class VI permits under the federal Safe Drinking Water Act’s (“SDWA”) Underground Injection Control (“UIC”) program for long-term carbon capture and sequestration (“CCS”).