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Environmental Appeals Board Ratifies First Group of Air Consent Agreements

Client Alert | 1 min read | 01.27.06

In an extensive opinion issued today, the Environmental Appeals Board ("EAB") took the final necessary step in EPA's administrative process and ratified twenty Animal Feeding Operations Air Consent Agreements. The EAB responded to numerous substantive challenges to the agreements raised by various citizen groups (including the Association of Irritated Residents and the Sierra Club) and held that the agreements comply with applicable statutory and regulatory requirements.

Now that the EAB has ratified these air consent agreements, EPA will coordinate the EAB's approval of the remaining 2,600+ agreements, which we expect will occur very quickly. The 20 agreements ratified today involved 10 swine and 10 egg farms.

We expect that the air monitoring studies will proceed shortly for the swine and egg species.

For a copy of the EAB's opinion and final order, click here.

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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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