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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.

Insights

Client Alert | 7 min read | 06.24.26

DOJ’s National Security Division Announces First Declination Under New Corporate Enforcement Policy With Parallel BIS Settlement

On June 17, 2026, the U.S. Department of Justice’s (DOJ( National Security Division (NSD) announced that it had issued a declination for Robert Bosch GmbH (Bosch) relating to potential violations of the Export Control Reform Act, 50 U.S.C. § 4819 (ECRA). Specifically, the DOJ declined to criminally prosecute Bosch’s violations of the Export Administration Regulations’ (EAR) Foreign Direct Product Rule (FDPR), which apparently resulted from two Bosch subsidiaries’ export of products and software manufactured with equipment that was the direct product of U.S. software or technology to Huawei Technologies Co., Ltd. and its “Entity List” affiliates, including Huawei Tech. Investment Co., Ltd., Hong Kong (collectively, Huawei). The same day, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a parallel civil administrative settlement with Bosch....