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ESG Investing is a “Significant Focus Area” for the SEC’s Division of Examinations

Following hot on the heels of the eagerly anticipated release of a proposed rule regarding climate-related disclosures (The Enhancement and Standardization of Climate-Related Disclosures for Investors), the Securities and...more

Update for Property Purchasers: PFAS, Phase Is, and CERCLA Protections

In the latest development surrounding PFAS, EPA has published a direct final rule endorsing use of the newly updated ASTM E1527-21 standard for Phase I Environmental Site Assessments (“Phase Is”)...more

The SEC’s Climate-Disclosures Proposed Rule – Eight Key Takeaways

The Securities and Exchange Commission (“SEC”) released a proposed rule on March 21, 2022, that would require U.S. and foreign private issuers to provide certain climate-related information in their registration statements...more

Environmental Groups Push for Broader PFAS Disclosure Requirements Under EPCRA

Several environmental groups recently filed a suit (the “Complaint”) challenging two EPA rules (the “PFAS rules”) that added a total of 175 PFAS chemicals to the list of toxic chemicals subject to reporting under what is...more

EPA’s Final Human Health Toxicity Assessment for PFAS GenX Chemicals

On October 25, 2021, the Environmental Protection Agency (“EPA”) released a final human health toxicity assessment for two PFAS substances — hexafluoropropylene oxide dimer acid and its ammonium salt — also known as “GenX...more

PFAS: Looking Back on a Year of Activity and Preparing for 2022

In 2021, there was sustained and fast-paced executive action from the Biden administration focused on emphasizing and addressing the environmental and human health effects of per- and poly-fluoroalkyl substances, more...more

Research, Restrict, and Remediate PFAS: What to Expect Next from EPA

The Environmental Protection Agency (“EPA”) launched its PFAS Strategic Roadmap: EPA’s Commitments to Action 2021-2024 (the “Roadmap”) on October 18, 2021. EPA presents the Roadmap as a comprehensive approach outlining the...more

EPA Announces Plans for Waste Rules That Could be a Stepping Stone to Drastically Expanding PFAS Liabilities

EPA announced plans for two separate rulemaking processes that would expand liabilities for PFAS wastes. The first — a rulemaking process to add certain PFAS chemicals as “hazardous constituents” under the Resource...more

EPA Reduces Renewable Fuel Standard Targets But Takes a Hard Line on Small Refinery Waivers

On December 7, 2021, the U.S. Environmental Protection Agency (“EPA”) proposed the long-awaited and much anticipated renewable fuel targets for 2020, 2021, and 2022 under the federal Clean Air Act’s (“CAA”) Renewable Fuel...more

COP26: Outcomes and Next Steps

The 2021 United Nations Climate Change Conference (COP26) produced some breakthrough pledges, a draft rulebook for an international carbon market, and some big aspirations. The agreement reflects a much more robust approach...more

Feds May Need Power To Take State Lands For New Grid

Ambitions to decarbonize the power sector by 2035 face a number of significant hurdles — the most intractable of which may be the extent of corresponding highvoltage transmission infrastructure necessary to accommodate the...more

EPA Takes Action on PFAS in Waste Water

In September 2021, the Environmental Protection Agency (“EPA”) released its Preliminary Effluent Guidelines Program Plan 15 (“Preliminary Plan 15”) which includes two new rulemakings that are intended to reduce Per- and...more

EPA Unveils Its Power Plants And Neighboring Communities Mapping Tool Further Addressing Environmental Justice Concerns

The Environmental Protection Agency (“EPA”) recently unveiled its new Power Plants and Neighboring Communities mapping tool as part of its commitment to Environmental Justice (“EJ”). The mapping tool displays: the location of...more

Speculative Report Opens PFAS Front Against Fracking

On July 12, 2021, Physicians for Social Responsibility (“PSR”) issued a highly speculative report that raised concerns about a chemical approved by the EPA in 2011 for use in hydraulic fracturing fluid that “might” degrade...more

Washington State’s Climate Change Fight: Clean Fuels Standards And Cap-And-Trade Program

Washington recently joined California, Oregon, and British Columbia in adopting a clean fuels standard that mandates reductions in greenhouse gas (“GHG”) emissions attributable to transportation fuels. In the final days...more

Are PFAS Air Emission Regulations On The Horizon?

While much of recent federal per- and polyfluoroalkyl substances (“PFAS”) regulatory activity has focused on water supply and soil contamination of PFAS compounds, the Environmental Protection Agency’s (“EPA”) ongoing...more

PFAS And The Transition To The Biden Administration: The Implications Of Designating PFOA And PFOS As “Hazardous Substances” Under...

In recent years, there has been no shortage of interest and commentary dedicated to a group of chemicals known collectively as PFAS. As one example, the potential designation of certain PFAS — PFOA and PFOS (perfluorooctanoic...more

PFAS: The “Forever Chemicals” In Consumer Products And Why Businesses Should Take Care In Their Marketing

PFAS (per- and poly-fluoroalkyl substances) have garnered significant national attention in the last few years. PFAS have made recent headlines in multi-million dollar settlements, Biden campaign promises, proposed EPA rules,...more

PFAS and the Transition To The Biden Administration: A Round-Up Of Recent PFAS Activity

Within the first month of the Biden administration, we have seen a high level of attention on per- and polyfluoroalkyl substances (“PFAS”). Increased focus on these “forever chemicals” is setting the stage for a challenging...more

“Immediately Effective” Midnight Rules — Beyond The Hour For Change Or Vulnerable To Court Challenges?

Ordinarily, the law governing how agencies create regulations — the Administrative Procedure Act — requires a thirty-day window between when a rule is published in the Federal Register and becomes “final” and when the rule is...more

Consolidated Appropriations Act Of 2021: Energy Financial Incentives

President Biden has announced ambitious energy and environmental goals in an effort to combat the effects of climate change. Many of the president’s goals hinge on increasing support for alternative forms of energy...more

Renewable Energy Under The Biden Administration And The Consolidated Appropriations Act Of 2021: Spurring Development

The Biden administration has committed to supporting increased renewable power generating capacity, calling to decarbonize the national electric grid by 2035. President Biden has already begun taking steps to support this...more

The PFAS Problem And The Transition To The Biden Administration: Looking Back And Setting The Stage For 2021

PFAS regulation is one of the hot environmental topics and a key issue to watch during this next year. In this series of posts, V&E will address the increasing regulatory attention concerning a group of chemicals known as...more

Biden Administration Environmental Justice Focus: Enforcement Impact

The Biden administration identified environmental justice (“EJ”) as a campaign priority1 and the Biden-Harris team has continually emphasized its commitment to environmental justice, stating that the administration would...more

The PFAS Problem And The Transition To The Biden Administration

PFAS regulation is one of the hot environmental topics and a key issue to watch during this next year. In this series of posts, V&E will address the increasing regulatory attention concerning a group of chemicals known as...more

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