Environmental Law

Wastewater Mixing Zones, Blending Rules and the “Tyranny of Small Decisions

Contact: Andrew C. Brought; Spencer Fane Britt & Browne LLP (Missouri, USA)

On March 25, 2013, the U.S. Court of Appeals for the Eighth Circuit sent a clear message to the EPA and other federal agencies: guidance documents and interpretive memoranda do not qualify as APA-compliant rulemaking. Iowa League of Cities v. EPA, slip op. No. 11-3412 (8th Cir. March 25, 2013).

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