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New International Court of Justice Advisory Opinion Raises Global Liability Stakes Around GHG Emissions and Climate Change amid...

The Opinion interprets member states’ responsibilities under treaty and customary international law. In a sweeping and landmark declaration, the Opinion advises that member states have a duty to reduce emissions, regulate...more

EPA Issues Second Extension of PFAS Reporting Timeline Under TSCA Section 8(a)(7)

On May 12, 2025, EPA announced that it will again revise the reporting timeline for manufacturers of per- and polyfluoroalkyl substances (PFAS) under Section 8(a)(7) of the Toxic Substances Control Act (TSCA). The data...more

EPA’s PFAS Strategy Evolves Amid Continued Regulatory, Legislative, and Litigation Uncertainty

While the Trump administration’s PFAS policy framework is beginning to take shape, uncertainties remain across the regulatory, litigation and legislative fronts. On April 28, EPA Administrator Lee Zeldin announced a set of...more

Presidential Memo Directs Immediate Repeal of Regulations Without Public Notice and Comment

Continuing with the Trump administration’s deregulatory agenda, the White House issued a Presidential Memorandum on April 9 titled Directing the Appeal of Unlawful Regulations. It instructs executive agencies to repeal...more

EPA Signals Potential PFAS Policy Pivot Under New Administrator

In March, EPA Administrator Lee Zeldin addressed top state environmental officials, highlighting the Agency’s priorities for the year ahead. Without committing the EPA to an official stance, Zeldin reaffirmed his commitment...more

Maryland Files PFAS Suit Against Downstream Manufacturer

Maryland has filed suit against W.L. Gore & Associates (Gore), a downstream user of PFAS-containing materials, alleging that its manufacturing processes contributed to PFAS contamination through its use of...more

Court Approves 60-Day Stays in Legal Battles over Biden-Era PFAS Regulations amid Administration Shift

In a move that signals potential policy shifts under the new administration, the U.S. Court of Appeals for the District of Columbia Circuit granted EPA’s requests for 60-day stays in two high-profile cases challenging...more

New York’s “Climate Superfund” Bill becomes Law, Part of a Trend

In a “paradigm shift in environmental liability,” some states are seeking to legislate financial responsibility on large coal and oil & gas companies for the public costs associated with strengthening infrastructure against...more

Carbon Sequestration Can Combat Global Warming, Sometimes in Unexpected Ways

Whether by land, by sea or through human innovation, carbon sequestration is likely coming to (or already happening in) a destination near you. As our planet, overdosed on greenhouse gases, battles climate disasters, a...more

EPA Tentatively Rejects the Center for Biological Diversity’s Petition to Regulate PVC as a Hazardous Waste

The EPA’s tentative determination signals the possibility of a future course reversal, and interested parties should consider making public comments, which could influence the outcome of the process. The U.S. Environmental...more

Proposed Rule to Designate Two PFAS Chemicals as Hazardous Substances Stands to Up the Ante for Site Remediation

EPA released a pre-publication notice of its long-anticipated proposed rule to designate certain PFOS and PFOA as CERCLA (Superfund) hazardous substances. CERCLA hazardous substances designation would fulfill an important...more

The Regulation of Medical Waste During COVID-19

The rapid spread of the coronavirus has generated new interest in the regulation of medical waste. The COVID-19 crisis is generating a significant amount of regulated medical waste....more

EPA’s Latest COVID-19 Guidance Addresses Field Work at Superfund Sites but Leaves Unaddressed Compliance Challenges for the...

Pandemic-related work stoppages and delays are affecting both field and non-field work at Superfund sites. COVID-19 is impacting Superfund site investigations and response activities. ...more

Supreme Court Affirms the Rights of States to Adjudicate State Law Claims Associated with Federal Superfund Sites

In landmark Arco decision, the U.S. Supreme Court held that state courts have jurisdiction to hear state law claims that involve sites with ongoing federal cleanup actions. CERCLA does not strip state courts of...more

COVID-19 Pandemic Will Soon be Impacting Compliance with and Enforcement of Environmental Laws

EPA existing guidance provides some conceptual anchoring for informing evolving risk management considerations. - Regulated parties face disruption of their ability to comply with environmental, health & safety laws due...more

EPA’s Wide-Ranging Rule on Perfluoroalkyl Substances

EPA continues its regulation of PFAS by shifting focus to the importation of certain PFAS-containing articles. - EPA goes for the low-hanging fruit by using TSCA to restrict the importation of long-chain PFAS that already...more

In a First-Ever Move, EPA Asks Industry and Public What Agency Regulations to Repeal, Replace or Modify

On April 13, 2017, the Environmental Protection Agency published a notice in the Federal Register seeking public comments on any “regulations that may be appropriate for repeal, replacement, or modification.” This...more

EPA Doubles Down with Expansive New Methane Regulation

The Obama administration took two major steps in implementing its comprehensive climate change strategy this month, setting first-ever methane emissions standards for new, reconstructed and modified sources and simultaneously...more

EPA Aircraft GHG Emissions Regulations Take Flight: Agency Announces Endangerment Finding for Aircraft Greenhouse Gas Emissions...

After tackling greenhouse gas (GHG) emissions from passenger vehicles and power plants, the Environmental Protection Agency (EPA) on June 10 announced its latest regulatory initiative—a GHG emissions standard for aircraft....more

Oil and Water: Proposed Redefinition of Waters of the U.S. Has Significant Implications for Domestic Operations

The Environmental Protection Agency (EPA) and the U.S. Army Corps of Engineers (ACOE) have announced a new Nov. 14, 2014, deadline to submit comments to its much-debated redefinition of the term, “Waters of the United...more

Supreme Court Roundup: Recent Environmental Law Rulings and Pending Cases

Scaling back considerably from the October 2012 Term, the United States Supreme Court issued only a few rulings affecting environmental law during the October 2013 Term. With significant pronouncements regarding EPA’s Clean...more

Texas Proposes New GHG Emissions Rules

In response to the standoff between the U.S. Environmental Protection Agency (EPA) and the State of Texas over EPA’s promulgation of new rules regulating stationary-source greenhouse gas (GHG) emissions, the Texas Legislature...more

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