February, 2015

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Tiny Beads, Big Problem: Vermont Seeks to Ban Microbeads

Vermont Law

Summary: There may be tiny bits of plastic in your toothpaste. These small plastic pieces are part of many personal care products and are designed to wash down the drain. However, due to their non-biodegradable nature and miniscule size, the plastic pellets sail through wastewater treatment plants, enter water bodies, and cause persistent environmental damage.

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Blurred Lines: The Importance of Delineation Between Legislative and Non-legislative Rules Under the APA

Vermont Law

Summary. : Not all agency rules have the force of law. In March of 2014, the EPA and the Army Corps of Engineers issued an “interpretive rule” regarding section 404 of the Clean Water Act, circumventing a notice and comment period. Under the Administrative Procedure Act (APA), “interpretive rules” are merely advisory and do not carry the force of law.