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EPA Issues New Deadlines for CAFO NPDES Permits and NMPs

Client Alert | 1 min read | 02.10.06

On February 10, 2006, EPA published a final rule to extend the current NPDES deadlines for CAFOs in response to last year's Waterkeeper Alliance, Inc. v. EPA decision from the Second Circuit (399 F.3d 486). EPA is extending all permitting and NMP deadlines from the 2003 CAFO Rule to July 31, 2007. Thus, "newly defined" CAFOs (those that were not defined as CAFOs by EPA prior to April 14, 2003) and existing CAFOs that meet EPA's new definition due to operational changes are no longer subject to the February 13, 2006 and April 13, 2006 deadlines for seeking NPDES permit coverage or the December 31, 2006 deadline for development and implementation of an NMP.

EPA stated in the proposed rule that it will issue an additional rulemaking "in mid 2006" to address the substantive issues raised in the Second Circuit's decision (i.e. duty to apply, NMP review, approval, and public participation requirements, etc.). The July 31, 2007 deadline may be extended or revised further in that subsequent rulemaking if necessary.

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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....