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Together, these developments will undoubtedly lead to more litigation and a higher cost of doing business on the Outer Continental Shelf. The number of civil penalty cases has risen gradually since 2009, with a sharp increase over 2013-2015. The civil penalty dollar amount has also grown significantly. million in civil penalties.
This language is nearly identical to that of Clean Air Act Section 202(a), which the Supreme Court held in Massachusetts v. EPA applies to greenhouse gases emitted from motor vehicles, and under which EPA issued an endangerment finding for greenhouse gases in 2009. Alternatively, the U.S.
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