Month: September 2025

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Key D.C. Circuit Decision Revives CAA Emergency Event Affirmative Defense

On September 5, 2025, the DC Circuit issued its opinion in SSM Litigation Group v. EPA, reversing EPA’s rescission of the longstanding emergency event affirmative defense under Title V of the Clean Air Act (“CAA”). The Court’s decision restores an important tool for all Title V sources facing potential enforcement as a result of emergency technological …

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Executive Order 14117 Comes into Force: Key Considerations for Cross-Border Data Transfers

What Happened? On January 8, 2025, the United States Department of Justice (“DOJ”) issued a final rule (“Final Rule”) to implement Executive Order 14117, “Preventing Access to Americans’ Bulk Sensitive Personal Data and United States Government-Related Data by Countries of Concern” (“EO 14117”). The Final Rule aims to restrict or prohibit certain categories of data …

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