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 is a trusted advisor to leading energy, oil and gas, mining, manufacturing, and industrial companies on their most complex and consequential environmental and natural resources matters. He counsels clients through high-stakes regulatory, permitting, enforcement, and policy challenges at the intersection of

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Eric Waeckerlin is a trusted advisor to leading energy, oil and gas, mining, manufacturing, and industrial companies on their most complex and consequential environmental and natural resources matters. He counsels clients through high-stakes regulatory, permitting, enforcement, and policy challenges at the intersection of major project development, air quality, and climate strategy, with a practice designed to support executive decision-making and enterprise-level risk management.

Eric is nationally recognized for his deep skills navigating the federal Clean Air Act (CAA) and its state analogues, and he routinely advises on permitting, compliance, and enforcement matters affecting large-scale conventional and low-carbon energy projects. His experience spans the full lifecycle of major projects—from early siting and permitting strategy through construction, operation, and defense of agency actions—allowing clients to move critical projects forward while managing regulatory, reputational, and financial risk. In addition to the CAA, Eric has substantial experience under the Resource Conservation and Recovery Act (RCRA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), and the National Environmental Policy Act (NEPA).

As energy markets evolve, Eric has been at the forefront of advising clients on climate and decarbonization strategies. He counsels companies on domestic and international climate and methane policy, including carbon capture and other CO₂ management regimes, emissions reduction and offset strategies, and participation in carbon and greenhouse gas markets. His work helps clients integrate highly complex regulatory compliance with broader sustainability, investment, and corporate strategy objectives.

In high-stakes litigation and regulatory challenges, Eric has served as lead counsel for national oil and gas trade associations in challenges to federal regulations and has successfully defended oil and natural gas companies in numerous multimillion-dollar air quality enforcement actions brought by the EPA and state agencies. Clients value his ability to combine technical regulatory knowledge with strategic judgment, making him a go-to counselor for executives and management teams navigating the legal risks shaping the future of energy.

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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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