After more than a decade of regulatory flip flopping on greenhouse gas emission limits from power plants and corresponding litigation, the U.S. Environmental Protection Agency proposes to rescind all GHG limits for fossil fuel-fired power plants promulgated under Clean Air Act Sections 111(b) and 111(d). On June 11, 2025, EPA issued a proposed rule that repeals carbon pollution standards for new and reconstructed gas turbines and existing and modified coal and oil/gas-fired units.

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Tags: clean air act, Environmental Protection Agency (EPA), EPA, GHG Emissions, greenhouse gas emissions, GT Insight
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Photo of Eric Waeckerlin Eric Waeckerlin

Eric Waeckerlin counsels clients across the energy, mining, solid and hazardous waste, manufacturing, and industrial sectors on a wide variety of complex environmental, public lands, and natural resources matters. Eric has been at the forefront of emerging legal and regulatory landscapes, with a

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Eric Waeckerlin counsels clients across the energy, mining, solid and hazardous waste, manufacturing, and industrial sectors on a wide variety of complex environmental, public lands, and natural resources matters. Eric has been at the forefront of emerging legal and regulatory landscapes, with a particular focus on air quality and climate change issues facing conventional and low-carbon energy development.

Eric focuses much of his practice on issues arising under the federal Clean Air Act (CAA) and has substantial experience advising clients on the Resource Conservation and Recovery Act (RCRA), the Clean Water Act (CWA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), and the National Environmental Policy Act (NEPA) as well as all delegated state equivalents. Eric is frequently called upon to represent companies in high-stakes federal and state enforcement, policy, and regulatory matters before the EPA, BLM, and state environmental agencies and oil and gas conservation commissions across the Rocky Mountain West.

As the energy landscape continues to change, Eric’s practice has evolved to meet his clients’ needs. He frequently counsels clients on domestic and international climate change and methane policy, including the Inflation Reduction Act’s Methane Emissions Reduction Program, CO2 management and capture and reduction strategies, and other issues affecting conventional and clean energy projects. In his litigation practice, Eric has served as lead counsel for national oil and gas trade associations in challenges to federal regulations. He has also defended oil and natural gas companies in multimillion dollar air quality enforcement actions brought by the EPA and related state agencies.

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Photo of Courtney M. Shephard Courtney M. Shephard

Courtney Shephard guides energy companies through complex regulatory landscapes in the Rocky Mountain West. Her experience spans conventional and low-carbon energy production, with a focus on federal regulatory compliance, permitting strategies, and resolving enforcement matters.

At the core of Courtney’s work is her

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Courtney Shephard guides energy companies through complex regulatory landscapes in the Rocky Mountain West. Her experience spans conventional and low-carbon energy production, with a focus on federal regulatory compliance, permitting strategies, and resolving enforcement matters.

At the core of Courtney’s work is her comprehensive approach to environmental compliance. She adeptly maneuvers through complex federal mandates—including NEPA, Clean Air Act, and Endangered Species Act requirements—and handles federal administrative appeals. Her experience includes crafting site-specific development strategies for localized development challenges that with the goal of achieving both environmental protection and development objectives.

Leveraging her background in climate policy analysis, carbon market dynamics, and emissions accounting, Courtney collaborates with clients to develop comprehensive carbon management strategies. Her practice includes methane and CO2 reduction strategies, Class VI storage permitting, and pore space acquisitions. She also represents clients in rulemaking and permitting proceedings before the Colorado Energy & Carbon Management Commission.

Access to adequate water supplies is a common project development challenge in the arid western United States. Courtney has more than a decade of experience working with private and municipal clients to appropriate, buy/sell, change, and protect water rights through private transactions and Colorado water court proceedings.

Courtney’s strategic vision and comprehensive understanding of regulatory frameworks have been instrumental in advancing numerous energy and infrastructure projects throughout the region. Her ability to synthesize complex regulatory requirements with practical business needs make her an asset to clients navigating the ever-changing energy landscape.

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Photo of Bernadette M. Rappold Bernadette M. Rappold

Bernadette M. Rappold focuses her practice on federal and state regulatory issues related to energy, manufacturing, and the environment. Bernadette has substantial litigation experience and advises clients on regulatory compliance as well as the environmental, safety, and health aspects of numerous business and…

Bernadette M. Rappold focuses her practice on federal and state regulatory issues related to energy, manufacturing, and the environment. Bernadette has substantial litigation experience and advises clients on regulatory compliance as well as the environmental, safety, and health aspects of numerous business and real estate transactions, including water, air, and chemical hazards. Bernadette offers clients perspective gained through years of service at the Environmental Protection Agency. While serving as a director of the Special Litigation and Projects Division in the Office of Civil Enforcement at the EPA’s Office of Enforcement and Compliance Assurance, Bernadette led complex enforcement actions in response to violations of the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, and other environmental statutes. Her work at the EPA covered a variety of economic and industrial sectors including the oil and gas, chemical, pharmaceutical, telecommunications, and agriculture industries.

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Photo of Jenna Rackerby Jenna Rackerby

Jenna Rackerby is a member of the Environmental Practice in Greenberg Traurig’s New York office. Jenna represents clients for environmental regulatory, transactional, and litigation matters, as well as related auditing and compliance issues, under the Clean Water Act (CWA), Clean Air Act (CAA),

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Jenna Rackerby is a member of the Environmental Practice in Greenberg Traurig’s New York office. Jenna represents clients for environmental regulatory, transactional, and litigation matters, as well as related auditing and compliance issues, under the Clean Water Act (CWA), Clean Air Act (CAA), National Environmental Policy Act (NEPA), and the New York State Environmental Quality Review Act (SEQRA). the Environmental Practice in Greenberg Traurig’s New York office.

Read more about Jenna RackerbyJenna's Linkedin Profile
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