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EPA Enforcement Trends and New Limits on Agencies' Use of Non-regulatory Guidance

Thursday, November 21, 2019 | 12:00 - 1:00 p.m. CT; 1:00 - 2:00 p.m. ET; lunch served at 11:30 a.m. CT, 12:30 p.m. ET | Houston, TX

Broadcast from our office in Houston to our Austin, Dallas, New York, Richmond, San Francisco and Washington offices. The program is also available via webcast.


Patrick Traylor, partner in the Environmental & Natural Resources Group, will present a CLE drawing from his experience as Deputy Assistant Administrator for the U.S. Environmental Protection Agency’s Office of Enforcement and Compliance Assurance (OECA). He will address this Administration’s national compliance initiatives, its policy on coordination between the federal government and states, and the challenges and opportunities facing the energy industry.

Conrad Bolston, senior associate in the Environmental & Natural Resources Group, will present on recent developments potentially limiting the use of guidance by agencies and increasing transparency and the implications for the energy industry. Conrad will cover:

  • Two October executive orders - one addressing transparency regarding guidance documents used and published by federal agencies, and the other promoting transparency and fairness in civil administrative enforcement
  • The recent interpretation of the Office of Management and Budget (OMB) clarifying that the Congressional Review Act applies to guidance documents.
  • A recent Supreme Court opinion describing the scope of the deference courts may show to an agency’s interpretation of its own regulations. 

Vinson & Elkins LLP is an accredited sponsor, approved by the State Bar of Texas Committee on MCLE. This course has been approved for Minimum Continuing Legal Education credit by the State Bar of Texas Committee on MCLE in the amount of 1.00 credit hours. Vinson & Elkins has been certified by the New York State Continuing Legal Education Board as an Accredited Provider of continuing legal education in the State of New York for the period of June 2, 2017 to June 1, 2020. This Transitional and Non-Transitional continuing legal education program has been approved in accordance with the Continuing Legal Education Board of the State of New York for a maximum of 1.00 credit hours, in the area of Professional Practice. Vinson & Elkins LLP is a Multiple Activity Provider for The State Bar of California. This activity is approved for 1.00 general hours. Vinson & Elkins is registered with the Texas State Board of Public Accountancy as a CPE sponsor. This registration does not constitute an endorsement by the board as to the quality of our CPE program. This course is eligible for 1.00 CPE credit hours, of which 1.00 hours can be applied to the area of Other. No prerequisites required.

    Venue

    Vinson & Elkins LLP - Houston Office
    1001 Fannin Street, Suite 2500
    Houston, TX 77002

    T +1.713.758.2222


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