September 26

Breaking News

Monsanto’s Weed Killer, Dicamba, Divides Farmers

Assignment

We are going to talk about deltas and Louisiana wetlands on Tuesday. This reading will carry over until Thursday. But take the opportunity over the weekend to read it, since it is dense going.

Read to B. POINT SOURCE, page 336.

This is dense reading. Rapanos is an important but crazy case, with no majority opinion.

Group assignments will follow.

Resources

Sea Level Rise Viewer

The Mississippi Delta Cycle and the Fate of Coastal Wetlands in the Face of Sea Level Rise

September 21

Breaking News

We will adjourn class on Thursday at 2:50 to allow you to attend the Energy Law Program described in the graphic below.

Assignment

Read to Problem: Vernal Pools and Intermittent Streams, p. 314.

Look at the two systems for classifying wetlands on the EPA site: https://www.epa.gov/wetlands/wetlands-classification-and-types

Since we will have an abbreviated class, and we are starting a new law, we  will do a general discussion of water and wetlands and pick up with problems next week.

Resources

Lemuel Shattuck – Report Of A General Plan For The Promotion Of General And Public Health Devised, Prepared And Recommended By The Commissioners Appointed Under A Resolve Of The Legislature Of Massachusetts, Relating To A Sanitary Survey Of The State. (1850)

The real beginning of the sanitation/clean water movement in the US.

William L. Andreen, The Evolution of Water Pollution Control in the United States—State, Local, and Federal Efforts, 1789–1972, Part I, 22 STAN. ENVTL. L.J. 145 (2003)

William L. Andreen, The Evolution of Water Pollution Control in the United States—State, Local, and Federal Efforts, 1789–1972, Part II, 22 STAN. ENVTL. L.J. 215 (2003).

The Mississippi Delta Cycle and the Fate of Coastal Wetlands in the Face of Sea Level Rise

September 19

Breaking News

The Looming Superfund Nightmare

CDC and Texas Health Officials Warn About Illness Linked to Raw Milk from Texas Dairy

Opinion: Why we need an international agreement on marine plastic pollution

Assignment

Finish Chapter 3.

Learning Objectives

Learn the regulatory trade 0ffs involved in the aggregation of sources into a bubble versus treating them as single sources.

Learn how mobile source regulation breaks from the shared federalism model.

Learn the role of tailoring rules.

Learn why the tailoring rule problem has been used to attack the regulation of GHGs as air pollutants.

Groups

I am dividing the class into groups of 4, based on the alphabet. When appropriate, I will make make group assignments as part of the class assignments. You still need to do the full assigned reading, but the groups will present their assigned topics and will have primary responsibility for material. This should make class discussions more interesting and effective. We will take 10 minutes at the beginning of class (be on time) for the groups to meet and discuss their presentations.

Groups A & B will work on Problem: Title V Permitting and Source Determination (pp. 245-60). A represents the company and B will take the position of an environment group that wants these sources aggregated.

Group C – take 10 minutes to tell us what is special about the regulation of MOBILE SOURCES, as compared to the regulation of stationary sources.

Groups D & E – What is the The Tailoring Rule and what legal problems does it post for GHG regulation? Look at the majority and the dissent in Utility Air Regulatory Group v. EPA 134 S. Ct. 2427 (2014), as well as any relevant regs or statutes in the book.

Group F – What is issue with BACT for GHG regulation and how does the court resolve this? What does the dissent say about it, and what problems do you anticipate with coming up with standards for it?

Group Last Name
A Barro
A Bounds
A Buller
A Cunningham
B Downer
B Dows
B DuBos
B Dupree
C Falcon
C Knister
C Leger
C Lemoine
D Long
D McBride
D Norfleet
D Pittman
E Ratnayaka
E Reinhardt
E Roy
E Sayers
F Stephens
F Stewart
F Thigpen
F Wilson

 

September 14

Breaking News

Harvey Spawns Air Pollution Problems In Houston

More Than 40 Sites Released Hazardous Pollutants Because of Hurricane Harvey

Assignment

Read to IX. Title V Permitting, p. 244

Work through the problems. That will be the focus of the class. Our objective is to figure out what lawyers do when confronted with these specific questions.

Learning Objectives – New Source Review

The CAA is divided between legacy sources and new – since the CAA – sources

The CAA has been amended several times and emissions standards have been tightened, based on new science and control technologies.

Each new set of regulations or tightening of regulations creates a new set of legacy sources.

A give facility may have sources that are under several different sets of requirements, depending on when they were built and/or permitted.

Resources

Hazardous Air Pollutants

Integrated Gasification Combined Cycle IGCC

New Source Review Workshop Manual (Draft) EPA (Oct. 1990) (Edited)

 

CAA § 111, 42 U.S.C. § 7411. Standards of performance for new stationary sources

(a)Definitions

For purposes of this section:

(1)The term “standard of performance” means a standard for emissions of air pollutants which reflects the degree of emission limitation achievable through the application of the best system of emission reduction which (taking into account the cost of achieving such reduction and any nonair quality health and environmental impact and energy requirements) the Administrator determines has been adequately demonstrated.

(2)The term “new source” means any stationary source, the construction or modification of which is commenced after the publication of regulations (or, if earlier, proposed regulations) prescribing a standard of performance under this section which will be applicable to such source.

(3)The term “stationary source” means any building, structure, facility, or installation which emits or may emit any air pollutant. Nothing in subchapter II of this chapter relating to nonroad engines shall be construed to apply to stationary internal combustion engines.

(4)The term “modification” means any physical change in, or change in the method of operation of, a stationary source which increases the amount of any air pollutant emitted by such source or which results in the emission of any air pollutant not previously emitted. * * *

(b)List of categories of stationary sources; standards of performance; information on pollution control techniques; sources owned or operated by United States; particular systems; revised standards

(1)(A)The Administrator shall, within 90 days after December 31, 1970, publish (and from time to time thereafter shall revise) a list of categories of stationary sources. He shall include a category of sources in such list if in his judgment it causes, or contributes significantly to, air pollution which may reasonably be anticipated to endanger public health or welfare.

(B)Within one year after the inclusion of a category of stationary sources in a list under subparagraph (A), the Administrator shall publish proposed regulations, establishing Federal standards of performance for new sources within such category. * * *

(2)The Administrator may distinguish among classes, types, and sizes within categories of new sources for the purpose of establishing such standards. * * *

 

§ 60.42Da.Standards for particulate matter (PM).

(a)Except as provided in paragraph (f) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8 [which requires a performance test within 180 days of startup], whichever date comes first, an owner or operator of an affected facility shall not cause to be discharged into the atmosphere from any affected facility for which construction, reconstruction, or modification commenced before March 1, 2005, any gases that contain PM in excess of 13 ng/J (0.03 lb/MMBtu) heat input. * * *

(c)Except as provided in paragraphs (d) and (f) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility that commenced construction, reconstruction, or modification after February 28, 2005, but before May 4, 2011, shall cause to be discharged into the atmosphere from that affected facility any gases that contain PM in excess of either:

(1)18 ng/J (0.14 lb/MWh) gross energy output; or

(2)6.4 ng/J (0.015 lb/MMBtu) heat input derived from the combustion of solid, liquid, or gaseous fuel. * * *

(e)Except as provided in paragraph (f) of this section [which is not relevant to this problem], the owner or operator of an affected facility that commenced construction, reconstruction, or modification commenced after May 3, 2011, shall meet the requirements specified in paragraphs (e)(1) and (2) of this section.

(1)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, the owner or operator shall not cause to be discharged into the atmosphere from that affected facility any gases that contain PM in excess of the applicable emissions limit specified in paragraphs (e)(1)(i) or (ii) of this section.

(i)For an affected facility which commenced construction or reconstruction:

(A)11 ng/J (0.090 lb/MWh) gross energy output; or

(B)12 ng/J (0.097 lb/MWh) net energy output.

(ii)For an affected facility which commenced modification, the emission limits specified in paragraphs (c) or (d) of this section.

(2)During startup periods and shutdown periods, owners or operators of facilities subject to subpart UUUUU of part 63 of this chapter shall meet the work practice standards specified in Table 3 to subpart UUUUU of part 63 and use the relevant definitions in § 63.10042, and owners or operators of facilities subject to subpart DDDDD of part 63 shall meet the work practice standards specified in Table 3 to subpart DDDDD of part 63 and use the relevant definition used in § 63.7575. * * *

§ 60.43Da.Standards for sulfur dioxide (SO2).

(a)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affected facility which combusts solid fuel or solid-derived fuel and for which construction, reconstruction, or modification commenced before or on February 28, 2005, except as provided under paragraphs (c), (d), (f) or (h) of this section, any gases that contain SO2 in excess of:

(1)520 ng/J (1.20 lb/MMBtu) heat input and 10 percent of the potential combustion concentration (90 percent reduction);

(2)30 percent of the potential combustion concentration (70 percent reduction), when emissions are less than 260 ng/J (0.60 lb/MMBtu) heat input;

(3)180 ng/J (1.4 lb/MWh) gross energy output; or

(4)65 ng/J (0.15 lb/MMBtu) heat input. * * *

(b)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator subject to the provisions of this subpart shall cause to be discharged into the atmosphere from any affected facility which combusts liquid or gaseous fuels (except for liquid or gaseous fuels derived from solid fuels and as provided under paragraphs (e) or (h) of this section) and for which construction, reconstruction, or modification commenced before or on February 28, 2005, any gases that contain SO2 in excess of:

(1)340 ng/J (0.80 lb/MMBtu) heat input and 10 percent of the potential combustion concentration (90 percent reduction); or

(2)100 percent of the potential combustion concentration (zero percent reduction) when emissions are less than 86 ng/J (0.20 lb/MMBtu) heat input.

(c)[Reserved by 77 FR 9450].

(d)Sulfur dioxide emissions are limited to 520 ng/J (1.20 lb/MMBtu) heat input from any affected facility which:

(1)Combusts 100 percent anthracite;

(2)Is classified as a resource recovery unit; or

(3)Is located in a noncontinental area and combusts solid fuel or solid-derived fuel.

(e)Sulfur dioxide emissions are limited to 340 ng/J (0.80 lb/MMBtu) heat input from any affected facility which is located in a noncontinental area and combusts liquid or gaseous fuels (excluding solid-derived fuels).

(f)The SO2 standards under this section do not apply to an owner or operator of an affected facility that is operated under an SO2 commercial demonstration permit issued by the Administrator in accordance with the provisions of § 60.47Da.

(g)Compliance with the emission limitation and percent reduction requirements under this section are both determined on a 30-day 238rolling average basis except as provided under paragraph (c) of this section. * * *

(i)Except as provided in paragraphs (j) and (k) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility for which construction, reconstruction, or modification commenced after February 28, 2005, but before May 4, 2011, shall cause to be discharged into the atmosphere from that affected facility, any gases that contain SO2 in excess of the applicable emissions limit specified in paragraphs (i)(1) through (3) of this section.

(1)For an affected facility which commenced construction, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output; or

(ii)5 percent of the potential combustion concentration (95 percent reduction).

(2)For an affected facility which commenced reconstruction, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output;

(ii)65 ng/J (0.15 lb/MMBtu) heat input; or

(iii)5 percent of the potential combustion concentration (95 percent reduction).

(3)For an affected facility which commenced modification, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output;

(ii)65 ng/J (0.15 lb/MMBtu) heat input; or

(iii)10 percent of the potential combustion concentration (90 percent reduction).

(j)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility that commenced construction, reconstruction, or modification commenced after February 28, 2005, and that burns 75 percent or more (by heat input) coal refuse on a 12-month rolling average basis, shall caused to be discharged into the atmosphere from that affected facility any gases that contain SO2 in excess of the applicable emission limitation specified in paragraphs (j)(1) through (3) of this section.

(1)For an affected facility for which construction commenced after February 28, 2005, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output on a 30-day rolling average basis; or

(ii)6 percent of the potential combustion concentration (94 percent reduction) on a 30-day rolling average basis.

(2)For an affected facility for which reconstruction commenced after February 28, 2005, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output on a 30-day rolling average basis;

(ii)65 ng/J (0.15 lb/MMBtu) heat input on a 30-day rolling average basis; or

(iii)6 percent of the potential combustion concentration (94 percent reduction) on a 30-day rolling average basis.

(3)For an affected facility for which modification commenced after February 28, 2005, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output on a 30-day rolling average basis;

(ii)65 ng/J (0.15 lb/MMBtu) heat input on a 30-day rolling average basis; or

(iii)10 percent of the potential combustion concentration (90 percent reduction) on a 30-day rolling average basis.

(k)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility located in a noncontinental area for which construction, reconstruction, or modification commenced after February 28, 2005, but before May 4, 2011, shall cause to be discharged into the atmosphere from that affected facility any gases that contain SO2 in excess of the applicable emissions limit specified in paragraphs (k)(1) and (2) of this section.

(1)For an affected facility that burns solid or solid-derived fuel, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain SO2 in excess of 520 ng/J (1.2 lb/MMBtu) heat input.

(2)For an affected facility that burns other than solid or solid-derived fuel, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain SO2 in excess of 230 ng/J (0.54 lb/MMBtu) heat input.

(l)Except as provided in paragraphs (j) and (m) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no 240owner or operator of an affected facility for which construction, reconstruction, or modification commenced after May 3, 2011, shall cause to be discharged into the atmosphere from that affected facility, any gases that contain SO2 in excess of the applicable emissions limit specified in paragraphs (l)(1) and (2) of this section.

(1)For an affected facility which commenced construction or reconstruction, any gases that contain SO2 in excess of either:

(i)130 ng/J (1.0 lb/MWh) gross energy output; or

(ii)140 ng/J (1.2 lb/MWh) net energy output; or

(iii)3 percent of the potential combustion concentration (97 percent reduction).

(2)For an affected facility which commenced modification, any gases that contain SO2 in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output; or

(ii)10 percent of the potential combustion concentration (90 percent reduction).

(m)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility located in a noncontinental area for which construction, reconstruction, or modification commenced after May 3, 2011, shall cause to be discharged into the atmosphere from that affected facility any gases that contain SO2 in excess of the applicable emissions limit specified in paragraphs (m)(1) and (2) of this section.

(1)For an affected facility that burns solid or solid-derived fuel, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain SO2 in excess of 520 ng/J (1.2 lb/MMBtu) heat input.

(2)For an affected facility that burns other than solid or solid-derived fuel, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain SO2 in excess of 230 ng/J (0.54 lb/MMBtu) heat input.

§ 60.44Da.Standards for nitrogen oxides (NOx).

* * *

(d)Except as provided in paragraph (h) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility that commenced construction, reconstruction, or modification after July 9, 1997, but before March 1, 2005, shall cause to be discharged into the atmosphere from that 241affected facility any gases that contain NOx (expressed as NO2) in excess of the applicable emissions limit specified in paragraphs (d)(1) and (2) of this section as determined on a 30-boiler operating day rolling average basis.

(1)For an affected facility which commenced construction, any gases that contain NOx in excess of 200 ng/J (1.6 lb/MWh) gross energy output.

(2)For an affected facility which commenced reconstruction, any gases that contain NOx in excess of 65 ng/J (0.15 lb/MMBtu) heat input.

(e)Except as provided in paragraphs (f) and (h) of this section, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility that commenced construction, reconstruction, or modification after February 28, 2005 but before May 4, 2011, shall cause to be discharged into the atmosphere from that affected facility any gases that contain NOx (expressed as NO2) in excess of the applicable emissions limit specified in paragraphs (e)(1) through (3) of this section as determined on a 30-boiler operating day rolling average basis.

(1)For an affected facility which commenced construction, any gases that contain NOx in excess of 130 ng/J (1.0 lb/MWh) gross energy output.

(2)For an affected facility which commenced reconstruction, any gases that contain NOx in excess of either:

(i)130 ng/J (1.0 lb/MWh) gross energy output; or

(ii)47 ng/J (0.11 lb/MMBtu) heat input.

(3)For an affected facility which commenced modification, any gases that contain NOx in excess of either:

(i)180 ng/J (1.4 lb/MWh) gross energy output; or

(ii)65 ng/J (0.15 lb/MMBtu) heat input.

(f)On and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, the owner or operator of an IGCC electric utility steam generating unit subject to the provisions of this subpart and for which construction, reconstruction, or modification commenced after February 28, 2005 but before May 4, 2011, shall meet the requirements specified in paragraphs (f)(1) through (3) of this section.

(1)Except as provided for in paragraphs (f)(2) and (3) of this section, the owner or operator shall not cause to be discharged into 242the atmosphere any gases that contain NOx (expressed as NO2) in excess of 130 ng/J (1.0 lb/MWh) gross energy output.

(2)When burning liquid fuel exclusively or in combination with solid-derived fuel such that the liquid fuel contributes 50 percent or more of the total heat input to the combined cycle combustion turbine, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain NOx (expressed as NO2) in excess of 190 ng/J (1.5 lb/MWh) gross energy output.

(3)In cases when during a 30-boiler operating day rolling average compliance period liquid fuel is burned in such a manner to meet the conditions in paragraph (f)(2) of this section for only a portion of the clock hours in the 30-day compliance period, the owner or operator shall not cause to be discharged into the atmosphere any gases that contain NOx (expressed as NO2) in excess of the computed weighted-average emissions limit based on the proportion of gross energy output (in MWh) generated during the compliance period for each of emissions limits in paragraphs (f)(1) and (2) of this section.

(g)Except as provided in paragraphs (h) of this section and § 60.45Da, on and after the date on which the initial performance test is completed or required to be completed under § 60.8, whichever date comes first, no owner or operator of an affected facility that commenced construction, reconstruction, or modification after May 3, 2011, shall cause to be discharged into the atmosphere from that affected facility any gases that contain NOx (expressed as NO2) in excess of the applicable emissions limit specified in paragraphs (g)(1) through (3) of this section.

(1)For an affected facility which commenced construction or reconstruction, any gases that contain NOx in excess of either:

(i)88 ng/J (0.70 lb/MWh) gross energy output; or

(ii)95 ng/J (0.76 lb/MWh) net energy output.

(2)For an affected facility which commenced construction or reconstruction and that burns 75 percent or more coal refuse (by heat input) on a 12-month rolling average basis, any gases that contain NOx in excess of either:

(i)110 ng/J (0.85 lb/MWh) gross energy output; or

(ii)120 ng/J (0.92 lb/MWh) net energy output.

(3)For an affected facility which commenced modification, any gases that contain NOx in excess of 140 ng/J (1.1 lb/MWh) gross energy output. * * *

 

 

September 12

Breaking News

Forest fires in the Northwest

This a severe respiratory threat throughout the Pacific northwest.

The West Is on Fire. Get Used to It.

Did air pollution create the hurricane drought?

4 Maps That Show the Gigantic Hurricane Irma Evacuation

They are now asking people to evacuate South Florida. Follow the process of evacuation and let’s hope it all works out. The key difference from Houston is storm surge. You cannot shelter in place if you are facing surge.

Interior Department sets Draconian limits on NEPA EIS review

Assignment

Read Chapter 3 to VI. New Source Review p216.

Resources

42 U.S. Code § 7502 – Nonattainment plan provisions in general

(2)RFP – Such plan provisions shall require reasonable further progress.

42 U.S. Code § 7503 – Permit requirements

(a)(1)(A) – attainment area

(a)(1)(B) – nonattainment areas

Louisiana SIP

LA DEQ

LA CAA Permits

Emission Offset Interpretative Ruling 40 C.F.R. Pt. 51, app. S (edited)

Ill – Section 203.302  Maintenance of Reasonable Further Progress and Emission Offsets

Ill – Section 203.303 Baseline and Emission Offsets Determination

 

 

 

September 7

Breaking news

Flooding risk for Florida

Assignment

Read Chapter 3 to V. State Implementation Plans, p.188

There are a lot of definitions that we will work through to get sense of the structure of the act. Read the problem and the associated material closely. It raises interesting issues political control.

Look at this graphic: Our Nation’s Air 2017 – United States Environmental Protection Agency 

PDF version from 2010: EPA – Our Nation’s Air STATUS AND TRENDS THROUGH 2010

Resources

Real time air quality map

Outdoor Air Quality – FDA – ozone and particulates

Villeneuve PJ, Chen L, Rowe BH, Coates F. Outdoor air pollution and emergency department visits for asthma among children and adults: A case-crossover study in northern Alberta, Canada. Environmental Health. 2007;6:40. doi:10.1186/1476-069X-6-40.

Clean Air Act Glossary

The Clean Air Act in a Nutshell:  How It Works. EPA (2013)

EPA – Air Quality – National Summary

 

 

 

September 5

Breaking News

The Secret History of FEMA

Keep your eye on Hurricane Irma

South Florida Water Management District – great hurricane site

EPA now requires political aide’s sign-off for agency awards, grant applications

Assignment

Finish Chapter 2. You can skip the edited version of Mass v. EPA. Most of this is background on enforcement, which is generally lost in law school courses because it is mostly outside the appeals court system.

Resources

Montreal Protocol

42 U.S. Code § 6928 – Federal enforcement RCRA

ESA § 11, 16 U.S.C. § 1540. Penalties and enforcement (g – citizen suits)

 

August 31

Breaking News

A little perspective on the Houston Flood

Assignment

Massachusetts v. E.P.A., 127 S.Ct. 1438 (2007)

Study Guide – Massachusetts v. E.P.A., 127 S.Ct. 1438 (2007)

We are going to read the long version of Mass v. EPA because it is a critical case and because it is a good review of some of the adlaw topics we have discussed. Read these materials carefully and be prepared to discuss the materials.

Resources

Slides – Climate Class – Massachusetts v. E.P.A., 127 S.Ct. 1438 (2007)

Warning – these are not lecture slides, they are slides designed to guide our discussion. They are mostly questions, not answers. They are subject to revision before class.

August 29

Recording of last class, Introduction to Administrative Law

Breaking News

Interior secretary recommends Trump alter at least three national monuments, including Bears Ears

Assignment

Read to IV. Constitutional Law and Environmental Law, p. 115

Resources

42 U.S.C. § 7607. Administrative proceedings and judicial review

 

 

August 24

Breaking News

What is in that bottled water?

Assignment

Read from II. Introduction to Statutory Interpretation (p80) to Problem: Challenging an EPA Rule (p98)

Resources

Slides – Introduction to Administrative Law

Reg Map for Informal Rulemaking – pdf

What does a rule look like?

Clean Water Rule: Definition of ‘‘Waters of the United States’’; Proposed Rule

Clean Water Rule: Definition of ‘‘Waters of the United States’’; Final Rule

What does a guidance document look like?

Enforcement Guidance: Reasonable Accommodation and Undue Hardship Under the Americans with Disabilities Act

Guidance to Federal Financial Assistance Recipients Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited English Proficient Persons