The Energy Law

JANUARY 10, 2013

By Lesley Foxhall Pietras On December 21, 2012, the Environmental Protection Agency (EPA) issued a policy announcement addressing how it will deal with source aggregation following the Sixth Circuit’s decision in Summit Petroleum Corp. v. EPA, 690 F.3d 733 (6th Cir. Aug. 7, 2012). (Our previous blog entry on this decision is available here.) In Summit , the Sixth Circuit concluded that the term “adjacent” implies only physical proximity, and EPA’s consideration of functional interrelatedness to

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The Energy Law

JANUARY 2, 2013

By Sarah Y. Dicharry and Robert E. Holden After Deepwater Horizon, the President directed the Secretary of the Interior to develop a report concerning safety on the Outer Continental Shelf (“OCS”). In response, the Secretary of the Interior drafted a report entitled, “Increased Safety Measures for Energy Development on the Outer Continental Shelf,” which recommended a number of actions to increase safety.

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