August 31, 2021 | Texas Lawyer
Check Your (Texas Audit) Privilege: It Might not be Available in Federal CourtThe Texas Audit Act is widely used by the regulated, who are incentivized by the regulator to look for, voluntarily disclose, and promptly correct violations in exchange for immunity from civil penalties.
By Eric Groten and Taylor Holcomb
7 minute read
December 05, 2017 | Texas Lawyer
Unwinding the FindingCombatants on both sides of the battle over regulating greenhouse gases see the 2009 Endangerment Finding as an on-off switch: With the Finding “on,”…
By Eric Groten
9 minute read
September 16, 2015 | Texas Lawyer
EPA Proposed Rule Could Resurrect Confusing Test for Air PermittingThe principal question is whether "adjacent" should have its ordinary meaning of "nearby" or proximate, or if it should include consideration of "functional interrelatedness." This definition would be used in EPA's Prevention of Significant Deterioration, Nonattainment New Source Review, and Title V permit program regulations.
By George C. Hopkins, Eric Groten and Jay Rothrock
6 minute read
September 16, 2015 | Texas Lawyer
EPA Proposed Rule Could Resurrect Confusing Test for Air PermittingThe principal question is whether "adjacent" should have its ordinary meaning of "nearby" or proximate, or if it should include consideration of "functional interrelatedness." This definition would be used in EPA's Prevention of Significant Deterioration, Nonattainment New Source Review, and Title V permit program regulations.
By George C. Hopkins, Eric Groten and Jay Rothrock
6 minute read