ERM and Bracewell Webinar series 2018

With so much happening at the US EPA all at once, ERM and Bracewell believe it will help the regulated community to have a forum for concise updates to aid in understanding and managing the business impacts and opportunities that these clean air reforms create. In addition to our June webinars, and our February 8th webinar on the reversal of USEPA’s once in, always in MACT policy, ERM and Bracewell will host another webinar in September to keep you up to date on additional policy changes throughout the year.

September 2018: Air Quality Policy Changes - Making sense of all the reforms

Since the beginning of the year, we have seen a dozen significant changes or proposed changes to air quality policies and regulations. Some of these actions merely point to changes to come, while others are immediately effective, and there are more coming in the near future.

This webinar included insights, recommendations, and real world examples around the following key topics:

  • Wheeler vs. Pruitt on Clean Air Policy
  • NSR reforms in proposed CPP Replacement Rule 
  • Project Aggregation Rule (w/ OMB since July 6th)
  • Cooperative Federalism and Enforcement
  • GHG Headlines: Clean Power Plan, Vehicle Stds, Methane
  • Q&A/Scorecard/Crystal Ball - Progress to date & what's next

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June 2018 Webinars: Making sense of all the memos

As USEPA promised, clean air policy changes are happening. Since the beginning of the year, we have seen ten or more significant changes to air quality policies and regulations. Some of these actions merely point to changes to come, while others are immediately effective.

With all of these significant changes taking place in such a short time frame, it is unclear to many companies how best to take advantage of the opportunities presented and where potential pitfalls lie.

June 7 - Singles and Doubles: What’s Going on with NSR?

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June 14 - Ongoing Improvements on Implementing the Clean Air Act

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February 2018: Reassessing MACT Compliance Options as the US EPA Ends the Once In Always In Policy

On Thursday, February 8th ERM and Bracewell hosted a webinar that took a legal and technical look at the US EPA’s January 25th memo reversing the long standing “once in, always in” policy.

The reversal of the “once in, always in” policy for MACT applicability presents opportunities for companies to enhance operational flexibility and reduce operating costs and compliance risk. With this policy change, facilities that are able to be permitted as “area sources” under Section 112 will generally be able to reduce the burden of paperwork, monitoring, recordkeeping and reporting requirements and comply with air quality requirements with greater certainty and less headache.

Listen to ERM and Bracewell's one-hour review of the new policy, the problems it solves and the questions and uncertainties that deserve further consideration.

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ERM's Insights

Read ERM's insights on the policy withdrawal including the potential benefits, reassessing your facility, timing and other considerations.


Read ERM and Bracewell's Frequently Asked Questions related to “Once In, Always In” and EPA’s January memo reversing the policy.