Enviro Watch



If you have any questions in regards to the above, please do not hesitate to contact our offices so that we may explain the amendments to the provisions of the Code in more detail. Our address is:


Fiddler González & Rodríguez, P.S.C., P.O. Box 363507, San Juan, PR 00936-3507. Our fax (787) 759-3108.


We welcome your questions and comments.

Juan Carlos Gómez Escarce
(787) 759-3166


María L. González Hernández
(787) 759-3173



Eduardo Negrón Navas

(787) 759-3106


Pedro J. Reyes Bibiloni

(787) 759-3208





The Puerto Rico Environmental Quality Board (EQB) promulgated Regulation No. 8546, a new Regulation for the Control of Underground Storage Tanks (UST). The new regulation entered into effect on January 23, 2015, and repeals Regulation No. 4362, the former UST regulation.


There are important changes to the regulatory requirements for UST, including the following: the elimination of certification requirements; the establishment of new permit requirements and financial assurance provisions; the modification of existing definitions, and incorporation of new ones such as classes of "operator"; the establishment of a field citation/penalty, “red tag” procedures, and filing fees; and the establishment of contaminant trace levels to be used during cleanup.


The changes in the new regulatory regime could render certain existing UST systems in non-compliance. EQB is considering establishing a moratorium to allow time to bring those UST into compliance.


If you are interested in learning and assessing the potential impacts Regulation No. 8546 may have in your operations, please contact us at your convenience.


If you know anyone that would like to receive the FGR Environmental Watch, please feel free to forward this newsletter or send us and e-mail in order to be added as recipient. Stay tuned for further updates of FGR ENVIRONMENTAL WATCH.





©2016 Fiddler, González & Rodríguez, P.S.C. This Watch has been prepared by Fiddler, González & Rodríguez, P.S.C. for informational purposes only and does not constitute legal advice. This information does not create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this without seeking advice from professional advisers. Fiddler, González & Rodríguez, P.S.C. and its members assume no responsibility to inform you of additional changes in law or any other legal issues related to the matters discussed in this publication.



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254 Muñoz Rivera Ave. 6th Floor

Hato Rey, Puerto Rico 00918


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PO Box 363507

San Juan, PR 00936-3507


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