CLEAR Act

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2308/S. 1246, FEMA Independence Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4357/S. 2260, Border Water Quality Restoration and Protection Act H.R. 4466, Cultivating Investment in Recycling and Circular Local Economies (CIRCLE) Act of 2025 H.R. 4669, Fixing Emergency Management for Americans (FEMA) Act of 2025 H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025 H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED) Tape Act H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act H.R. 6832, Packaging and Claims Knowledge Act H.R. 7502, Recycled Materials Attribution Act H.R. 7567, Farm, Food, and National Security Act of 2026 H.R. 8800, FY 27 National Defense Authorization Act H.R. 9250, Great American Outdoors Act 250 H.R. 9317, Buses Utilizing Safety and Environmental Standards (BUSES) Act H.R. 9497/S. 4949, Water Resources Development Act of 2026 H.R. 9760/S. 5035, National Coordination on Adaptation and Resilience for Security Act of 2026 S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) Act of 2025 S. 623, No IRIS Act of 2025 S. 1323, Facilitating Increased Resilience, Environmental Weatherization and Lowered Liability Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3305, Curtailing Litigation Excess and Abuse Reform (CLEAR) Act of 2025 S. 3826, Modernizing Clean Air Permitting Act S.4944, American Energy and Mineral Infrastructure Act of 2026 H.J. Res. 61/S.J. Res. 11, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J. Res. 87/S.J. Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J. Res. 88/S.J. Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J. Res. 89/S.J. Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" H.J. Res. 205, S.J. Res. 207, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle Pollution Control Standards; Notice of Decision Granting a Waiver of Clean Air Act Preemption for California's Advanced Clean Car Program and a Within the Scope Conformation for California's Zero Emission Vehicle Amendments for 2017 and Earlier Model Years" H.J. Res. 210, S.J. Res. 210, Commercial Harbor Craft Regulations Waiver, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Nonroad Engine Pollution Control Standards; Ocean-Going Vessels At-Berth; Notice of Decision" H.J. Res. 211, S.J. Res. 206, Providing congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle Pollution Control Standards; Notice of Decision Granting a Waiver of Clean Air Act Preemption for California's 2009 and Subsequent Model Year Greenhouse Gas Emission Standards for New Motor Vehicles" H.J. Res. 212, S.J. Res. 208, Providing congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Notice of Decision" S.J. Res. 187, Disapproving EPAs Modification to the Start of the Submission Period for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Reporting and Recordkeeping Under TSCA 8(a)(7) Discussion draft legislation To amend the Federal Water Pollution Control Act to exempt civil penalties for certain violations of such Act from the Federal Civil Penalties Inflation Adjustment Act of 1990, and for other purposes Discussion draft legislation to reform the Brownfields Program Draft legislation titled Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act - Discussion Draft Draft legislation titled Water Cost Accountability Act Draft legislation titled Safe Drinking Water Infrastructure Improvement Act of 2026 Draft Chemical Research and Development Testbed bill Draft legislation titled Methane Emissions Assessment to Secure the Unions Role in Energy (MEASURE) Act of 2026 Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation on PFAS Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Draft legislation relating to the reform of NEPA, NHPA and other statutes as part of broader efforts to modernize federal environmental permitting Potential legislation regarding TSCA reform Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1721, the Health H20 Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 2964, Wastewater Infrastructure Pollution Prevention and Environmental Safety Act Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S.3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J. Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J.Res. 117/S.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con.Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislation similar to S.Con.Res.14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Rescission of Regulatory Determinations and Removal of Related Provisions for Four PFAS Substances (91 Fed. Reg. 29,413, May 20, 2026) Extending the Compliance Deadline for the PFOA and PFOS Maximum Contaminant Levels (91 Fed. Reg. 29,425, May 20, 2026) Revisions to Establish the Sixth Unregulated Contaminant Monitoring Rule for Public Water Systems; EPA-HQ-OW-2023-0469; FRL-10857-03-OW, August 31, 2026 Draft Guidance for Reducing Risk From Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonic Acid (PFOS) in Biosolids; Establishment of a Public Docket; Request for Feedback (EPA-HQ-OW-2026-2509; FRL-13318-01-OW) DPAS Directive: Allocation Order and Additional Requirements for Recoverable Critical Minerals and Material Updated Definition of Waters of the United States; EPA-HQ-OW-2025-0322; RIN 2040-AG44 Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2021-0585, Compliance Deadline Extension and ANPRM for CWA Section 311 Worst Case Spill Program, (91 Fed. Reg. 10,787, March 5, 2026) Proposed rule: withdrawal of proposed provision, regarding Docket ID No. EPA-HQ-OAR-2003-0156, EPA Rule on Pyrolysis Clean Air Act Exclusion, (86 Fed. Reg. 50,296, May 24, 2023) Proposed rescission of the hazard index (HI) for select PFAS and extension of the compliance deadline for implementation of the National Primary Drinking Water Standard for PFOA and PFOS Proposed interim guidance for PFAS disposal and destruction Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2025-1707, Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration, (91 Fed. Reg. 7,415-7,420, February 18, 2026) Proposed Rule, Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 Fed. Reg. 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Final Rule, Partial Repeal of Carbon Pollution Standards for Fossil Fuel-Fired Electric Generating Units (91 Fed. Reg. 58,954-59,000, September 17, 2026) Supplemental Notice of Proposed Rulemaking, Rescission of the Greenhouse Gas Findings for Fossil Fuel-Fired Power Plants and Repeal of Regulations for Power Plant Greenhouse Gas Emissions Under Clean Air Act Section 111 (91 Fed. Reg. 59,002-59,046, September 17, 2026) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216-72,312, October 19, 2023) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150 - 27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) of the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 (December 29, 2025) A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams (November 25, 2025) Comments on Proposed Revisions to the AIM Act Technology Transition Rule (Docket No. EPA-HQ-OAR-2025-0005) (November 21, 2025) Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272 (August 6, 2025) Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16; Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Various issues relating to regulatory permit streamlining; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; reauthorization of Water Resources Development Act (P.L. 118-272); National Environmental Policy Act permitting modernization and CEQ regulatory updates; Water Infrastructure Finance and Innovation Act expansion; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers and specifically disposal and destruction; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; Congressional Review Act disapproval of regulations; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; implementation of the EU Methane Regulations; Endangered Species Act regulations and legislation; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; comments on the 2026 UN Water Conference themes; petition to EPA to designate solar panels as universal waste; petition for EPA, OSHA, and OMB to establish a single, consistent federal regulatory framework for worker chemical safety under Section 9 of the Toxic Substances Control Act (TSCA); principles of TSCA Risk Management under Section 6; meeting and continuing correspondence with House Oversight Majority office on Greenhouse Gas Protocol scope 2 updates & a standard being developed for GHGP by ISO; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); EUREACH PFAS restrictions/SEAC consultation; FTC Green Guides; Global Plastics Pollution Agreement; Basel Convention implementing legislation; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; Proposed a Clean Water Act Section 404c Veto, June 18, 2026; Clean Water and Drinking Water State Revolving Funds (SRFs); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); Water and Resilience Provisions (IIJA, P.L. 117-58); reauthorization of the Drinking Water and Wastewater Infrastructure Act (P.L. 117-58, Title XII, Div. E); implementation of the Safe Drinking Water Act (P.L. 93 523); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); disaster preparedness and emergency management reform; pre-disaster mitigation and resilience funding

Client expense: $16,480,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Intl Trade Administration (ITA), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

Clean Air Act; National Ambient Air Quality Standards; National Emissions Standards for Hazardous Air Pollutants; Resource Conservation and Recovery Act; Carbon Capture, Utilization, Transmission, and Storage; Permitting Reform; New Source Review Permitting Act (H.R. 161); Resilience; Alternative Fuels; Alternative Fuels Non Hazardous Waste Rule; Coal Combustion Residuals; Implementation of the Inflation Reduction Act (P.L. 117-116); Implementation of the Infrastructure Investment and Jobs Act (P.L. 117-58); IMPACT Act (HR 1534); Concrete and Asphalt Innovation Act (S. 1067); Portland Cement National Emissions Standards for Hazardous Air Pollutants; Coal Ash for Infrastructure Act (H.R. 4875); SPEED Act (H.R. 4776); Reauthorization of EPA Water Infrastructure Programs; H.R.4214: Clean Air and Building Infrastructure Improvement Act; H.R.4218: Clean Air and Economic Advancement Reform (CLEAR) Act; H.R.6409: Foreign Emissions & Nonattainment Clarification for Economic Stability(FENCES) Act; H.R.6398: Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R.6387: Fire Improvement and Reforming Exceptional Events (FIRE) Act; Executive Order - Seeking Federal Recognition of Cement as a Critical National Security Material; Reforming Cement Manufacturing for Enhanced Material Efficiency and New Technology Act, ReCement Act (H.R. 9293); Bipartisan American Affordability and Jobs Act (S. 5653); American Energy and Mineral Infrastructure Act (S. 4944)

Client expense: $390,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office

Oil and Natural Gas Sector: Emissions Standards for New, Reconstructed, and Modified Sources Review (EPA-HQ-OAR-2021-0317). Implementation Plan for the 2015 Ozone National Ambient Air Quality Standards (EPA-HQ-OAR-2021-0668; FRL 8670-02-OAR). Request for Information - Inflation Reduction Act Provisions for the Office of Air and Radiation Implementation (EPA-HQ-OAR-2022-0875; EPA-HQ-OAR-2022-0878). Federal policy relating to the role of natural gas infrastructure in achieving sustainability goals, including measures to lessen methane intensity and promote innovation and investment. H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act (provisions relating to the interstate natural gas pipeline sector). H.R. 1, One Big Beautiful Bill Act (provisions relating to the interstate natural gas pipeline sector). H.R. 161, New Source Review (NSR) Permitting Improvement Act (provisions relating to the interstate natural gas pipeline sector). H.R. 4218, Clean Air and Economic Advancement Reform Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability Act (provisions relating to the interstate natural gas pipeline sector). S. 5653, Bipartisan American Affordability and Jobs Act of 2026 (provisions relating to the interstate natural gas pipeline sector).

Client expense: $267,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Plastic Waste / Advanced Recycling; PFAS; CFATS Reauthorization; State Polluter Pays Retroactive Penalty provisions and related issues; TSCA Reform; Endangered Species Act Reauthorization/Reform; The Hazardous Organic National Emission Standards for Hazardous Air Pollutants (HON Rule) H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act

Client expense: $1,520,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act; California Clean Air Act Waivers; Corporate Average Fuel Economy Standards; H.R. 8330 / S. 434

Client expense: $1,520,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 1897, ESA Amendments Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2308/S. 1246, FEMA Independence Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3617, Securing Americas Critical Minerals Supply Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4357/S. 2260, Border Water Quality Restoration and Protection Act H.R. 4466, CIRCLE Act H.R. 4503/S. 3800, ePermit Act H.R. 4669, FEMA Act H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025 H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED) Tape Act H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act H.R. 7502, the Recycled Materials Attribution Act H.R. 7567, Farm, Food, and National Security Act of 2026 H.R. 7845, Drought Relief Obtained Using Government Help Today Act of 2026 H.R. 8800, FY 27 National Defense Authorization Act H.R. 9250, Great American Outdoors Act 250 H.R. 9317, Buses Utilizing Safety and Environmental Standards (BUSES) Act S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) Act of 2025 S. 623, No IRIS Act of 2025 S. 1323, Facilitating Increased Resilience, Environmental Weatherization and Lowered Liability Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3305, Curtailing Litigation Excess and Abuse Reform (CLEAR) Act of 2025 S. 3826, Modernizing Clean Air Permitting Act S. 3967, Futureproofing Local Operations for Water Systems Act H.J. Res. 61/S.J. Res. 11, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J. Res. 87/S.J. Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J. Res. 88/S.J. Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J. Res. 89/S.J. Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" Discussion draft legislation To amend the Federal Water Pollution Control Act to exempt civil penalties for certain violations of such Act from the Federal Civil Penalties Inflation Adjustment Act of 1990, and for other purposes. Discussion draft legislation to reform the Brownfields Program Draft legislation titled Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act - Discussion Draft Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation titled The American Energy and Mineral Infrastructure Act Draft legislation on PFAS Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Draft legislation relating to the reform of NEPA, NHPA and other statutes as part of broader efforts to modernize federal environmental permitting Potential legislation regarding TSCA reform Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1721, the Health H20 Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 2964, Wastewater Infrastructure Pollution Prevention and Environmental Safety Act; Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J. Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J. Res. 117/S.J. Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con. Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislative action similar to S.Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Proposed rescission of the hazard index (HI) for select PFAS and extension of the compliance deadline for implementation of the National Primary Drinking Water Standard for PFOA and PFOS Proposed interim guidance for PFAS disposal and destruction Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2025-1707, Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration, (91 Fed. Reg. 7,415-7,420, February 18, 2026) Proposed Rule, Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 Fed. Reg. 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Availability and Request for Comment on Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (86 Fed. Reg. 24,669-24,670, May 7, 2021) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216-72,312, October 19, 2023) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150 - 27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,610-10,616, February 25, 2025) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Notice; request for information (RFI), Office of Acquisition Policy, General Services Administration, Notice of Inquiry Regarding PFAS in Products; (89 Fed. Reg. 26,887-26,888, April 16, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Circularity for Secure and Sustainable Products and Materials: A Draft Strategic Framework Request for Information (EERE T 540.111-02, October 9, 2024) Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 68,894-68,896, August 28, 2024) Notice of Availability, Proposed High-Priority Substance Designations Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 60,420-60,424, July 25, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 (December 29, 2025) A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams (November 25, 2025) Comments on Proposed Revisions to the AIM Act Technology Transition Rule (Docket No. EPA-HQ-OAR-2025-0005) (November 21, 2025) Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272 (August 6, 2025) Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16 Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2021-0585, Compliance Deadline Extension and ANPRM for CWA Section 311 Worst Case Spill Program,(91 Fed. Reg 10,787, March 5, 2026) Proposed rule: withdrawal of proposed provision, regarding Docket ID No. EPA-HQ-OAR-2003-0156, 'EPA Rule on PyrolysisClean Air ActExclusion,(86 Fed. Reg. 50,296, May 24, 2023) Regulatory review; request for public comment Regarding RIN 3084-AB15, Needed Updates to the FTC Green Guides,(89 Fed. Reg. 67,335 - 67,336, August 20, 2024 Notice: solicitation of Input regarding docket number COE-2026-0001 ,U.S. Army Corps Nationwide Permit RFI,(Fed. Reg 12,591 - 12,593, March 16, 2026) Notice of availability; request for comments regarding Docket ID Number EPA-HQ-OW-2022-0946, Safe Drinking Water Act Contaminant Candidate List 6, (88 Fed. Reg 10,316 - 10,318, April 18, 2023) Open Federal Advisory Committee meeting.Regarding Docket No. DHS-2025-0712, FEMA ReviewCouncilreport,(90 Fed. Reg. 54,360, November 26, 2025) Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Notice ID: DODCMRMP05272025, Department of Defense Request for Information; Chemical and Material Risk Management Program (CMRMP) Toxic Substances Control Act (TSCA) Market Analysis (June 20, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat, (90 Fed. Reg. 52,607-52,615, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat, (90 Fed. Reg. 52,592-52,599, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Interagency Cooperation Regulations, (90 Fed. Reg. 52,600-52,607, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants (90 Fed. Reg. 52,587-52,592, November 21, 2025) Various issues relating to regulatory permit streamlining; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; reauthorization of Water Resources Development Act (P.L. 118-272); National Environmental Policy Act permitting modernization and CEQ regulatory updates; Water Infrastructure Finance and Innovation Act expansion; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; Congressional Review Act disapproval of regulations; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; implementation of the EU Methane Regulations; Endangered Species Act regulations and legislation; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; submitted comments on the RFI for the 2026 UN Water Conference thematic issues request for information; petition to EPA to designate solar panels as universal waste; meeting and continuing correspondence with House Oversight Majority office on Greenhouse Gas Protocol scope 2 updates & a standard being developed for GHGP by ISO; implementation of Outer Continental Shelf Lands Act (P.L. 83-212) Notice of Objection and Request for Board of Review in relation to the Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999; FTC Green Guides; Global Plastics Pollution Agreement; Basel Convention implementing legislation; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; Clean Water and Drinking Water State Revolving Funds (SRFs); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); Water and Resilience Provisions (IIJA, P.L. 117-58); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); reauthorization of the Drinking Water and Wastewater Infrastructure Act (P.L. 117-58, Title XII, Div. E); implementation of the Flood Level Observation, Operations, and Decision Support Act (P.L. 117‑316); implementation of the Safe Drinking Water Act (P.L. 93‑523); implementation of Frank R. Lautenberg Chemical Safety for the 21st Century Act (P.L. 114-182); disaster preparedness and emergency management reform; pre-disaster mitigation and resilience funding; rural community water assistance programs

Client expense: $16,950,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

H.R. 3616, Reliable Power Act H.R. 1047, GRID Power Act H.R.2986 Expediting Generator Interconnection Procedures Act of 2025 H.R. 5600, Speed and Reliability Act of 2025 H.R. 4218, Clean Air and Economic Advancement Reform (CLEAR) Act (Rep. Carter) S. _____ Senate Democratic Discussion Draft Transmission Bill (Padilla) H.R. 7977, Energy Bills Relief Act H.R. 2703, Advancing GETs Act H.R. 9340, Ratepayer Protection Act S. 3518, FLOWS Act H.R. 9337, Hydropower Licensing Affordability Act

Client expense: $70,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling HR 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act HR 4218, Clean Air and Economic Advancement Reform (CLEAR) Act HR 4214, Clean Air and Building Infrastructure Improvement Act HR 161, New Source Review Permitting Improvement Act HR 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) HR 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act HR 6373, Air Permitting Improvements to Protect National Security Act HR 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act

Client expense: $710,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Lobbied in response to the U.S. Environmental Protection Agency's Integrated Iron & Steel Risk and Technology Review, EPA's Taconite Iron Ore Processing Source Category rule, EPA's National Emission Standards for Hazardous Air Pollutants for Coke Ovens, and EPA's National Emission Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Technology Review. Lobbied in support of Clean Air Act (CAA) Reform Legislation: H.R. 4218, the Clean Air and Economic Advancement Reform (CLEAR) Act, to allow technological and economic feasibility factors to be used by EPA for air quality standard decisions, as well as to extend the NAAQS review cycle from five years to 10 years. H.R.6387, the Fire Improvement and Reforming Exceptional Events (FIRE) Act, to appropriately permit air emissions resulting from exceptional events to be excluded from the NAAQS attainment designations. H.R.6409, the Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act, to similarly clarify that emissions emanating from outside of the U.S. can be excluded from designation decisions. H.R.4214, the Clean Air and Building Infrastructure Improvement Act, to amend the CAA to ensure regulated facilities have EPAs full implementation guidance prior to having to meet final NAAQS standards. H.R.161, the New Source Review Permitting Improvement Act, to clarify that modifications to existing facilities trigger New Source Review (NSR) permitting requirements only when the sources maximum achievable hourly emission rate is increased. The Ratepayer Protection Act - H.R. 9340. Engaged in response to the definition of "Large Load Customer".

Client expense: $630,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

AI and copyright issues. H.R.4218 - CLEAR Act. H.R.7209/S.2455 - TRAIN Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, White House Office

Oil and Natural Gas Sector: Emissions Standards for New, Reconstructed, and Modified Sources Review (EPA-HQ-OAR-2021-0317). Implementation Plan for the 2015 Ozone National Ambient Air Quality Standards (EPA-HQ-OAR-2021-0668; FRL 8670-02-OAR). Request for Information - Inflation Reduction Act Provisions for the Office of Air and Radiation Implementation (EPA-HQ-OAR-2022-0875; EPA-HQ-OAR-2022-0878). Federal policy relating to the role of natural gas infrastructure in achieving sustainability goals, including measures to lessen methane intensity and promote innovation and investment. H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act (provisions relating to the interstate natural gas pipeline sector). H.R. 1, One Big Beautiful Bill Act (provisions relating to the interstate natural gas pipeline sector). H.R. 161, New Source Review (NSR) Permitting Improvement Act (provisions relating to the interstate natural gas pipeline sector). H.R. 4218, Clean Air and Economic Advancement Reform Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability Act (provisions relating to the interstate natural gas pipeline sector).

Client expense: $275,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Clean Air Act; National Ambient Air Quality Standards; National Emissions Standards for Hazardous Air Pollutants; Resource Conservation and Recovery Act; Carbon Capture, Utilization, Transmission, and Storage; Permitting Reform; New Source Review Permitting Act (H.R. 161); Resilience; Alternative Fuels; Alternative Fuels Non Hazardous Waste Rule; Coal Combustion Residuals; Implementation of the Inflation Reduction Act (P.L. 117-116); Implementation of the Infrastructure Investment and Jobs Act (P.L. 117-58); IMPACT Act (HR 1534); Concrete and Asphalt Innovation Act (S. 1067); Portland Cement National Emissions Standards for Hazardous Air Pollutants; Coal Ash for Infrastructure Act (H.R. 4875); SPEED Act (H.R. 4776); Reauthorization of EPA Water Infrastructure Programs; H.R.4214: Clean Air and Building Infrastructure Improvement Act; H.R.4218: Clean Air and Economic Advancement Reform (CLEAR) Act; H.R.6409: Foreign Emissions & Nonattainment Clarification for Economic Stability(FENCES) Act; H.R.6398: Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R.6387: Fire Improvement and Reforming Exceptional Events (FIRE) Act; Executive Order - Seeking Federal Recognition of Cement as a Critical National Security Material; Reforming Cement Manufacturing for Enhanced Material Efficiency and New Technology Act, ReCement Act (H.R. 9293)

Client expense: $360,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2308/S. 1246, FEMA Independence Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3617, Securing Americas Critical Minerals Supply Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4357/S. 2260, Border Water Quality Restoration and Protection Act H.R. 4466, CIRCLE Act H.R. 4503, ePermit Act H.R. 4669, FEMA Act H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025 H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED) Tape Act H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act H.R. 7567, Farm, Food, and National Security Act of 2026 S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) Act of 2025 S. 623, No IRIS Act of 2025 S. 1323, Facilitating Increased Resilience, Environmental Weatherization and Lowered Liability Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3305, Curtailing Litigation Excess and Abuse Reform (CLEAR) Act of 2025 S. 3826, Modernizing Clean Air Permitting Act H.J. Res. 61/S.J. Res. 11, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J. Res. 87/S.J. Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J. Res. 88/S.J. Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J. Res. 89/S.J. Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" H.J. Res. 140, Superior National Forest Mineral Withdrawal CRA Resolution Discussion draft legislation To amend the Federal Water Pollution Control Act to exempt civil penalties for certain violations of such Act from the Federal Civil Penalties Inflation Adjustment Act of 1990, and for other purposes Discussion draft legislation to reform the Brownfields Program Draft legislation titled Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act - Discussion Draft Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation on PFAS Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Draft legislation relating to the reform of NEPA and other statutes as part of broader efforts to modernize federal environmental permitting Draft legislation titled the Recycled Materials Attribution Act (RMAA) Potential legislation regarding the reauthorization of surface transportation programs Potential legislation regarding TSCA reform Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S.3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 8030/S. 4134, Drought Relief Obtained Using Government Help Today Act of 2024 Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J. Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J. Res. 117/S.J. Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con. Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislation similar to S.Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Proposed rescission of the hazard index (HI) for select PFAS and extension of the compliance deadline for implementation of the National Primary Drinking Water Standard for PFOA and PFOS Proposed interim guidance for PFAS disposal and destruction Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2025-1707, Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration, (91 Fed. Reg. 7,415-7,420, February 18, 2026) Proposed Rule, Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 Fed. Reg. 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Availability and Request for Comment on Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (86 Fed. Reg. 24,669-24,670, May 7, 2021) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216-72,312, October 19, 2023) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150-27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,610-10,616, February 25, 2025) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Notice; request for information (RFI), Office of Acquisition Policy, General Services Administration, Notice of Inquiry Regarding PFAS in Products; (89 Fed. Reg. 26,887-26,888, April 16, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Circularity for Secure and Sustainable Products and Materials: A Draft Strategic Framework Request for Information (EERE T 540.111-02, October 9, 2024) Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 68,894-68,896, August 28, 2024) Notice of Availability, Proposed High-Priority Substance Designations Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 60,420-60,424, July 25, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 (December 29, 2025) A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams (November 25, 2025) Comments on Proposed Revisions to the AIM Act Technology Transition Rule (Docket No. EPA-HQ-OAR-2025-0005) (November 21, 2025) Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272 (August 6, 2025) Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16 Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Notice ID: DODCMRMP05272025, Department of Defense Request for Information; Chemical and Material Risk Management Program (CMRMP) Toxic Substances Control Act (TSCA) Market Analysis (June 20, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat, (90 Fed. Reg. 52,607-52,615, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat, (90 Fed. Reg. 52,592- 52,599, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Interagency Cooperation Regulations, (90 Fed. Reg. 52,600-52,607, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants (90 Fed. Reg. 52,587-52,592, November 21, 2025) Various issues relating to regulatory permit streamlining; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; U.S.-Mexico water policy; energy security and its relationship to national security; phasing out of hydrofluorocarbons (HFCs); reauthorization of Water Resources Development Act (P.L. 118-272); National Environmental Policy Act permitting modernization and CEQ regulatory updates; Water Infrastructure Finance and Innovation Act expansion; Canadian plastics consultations; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; Congressional Review Act disapproval of regulations; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; implementation of the EU Methane Regulations; Endangered Species Act regulations and legislation; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; comments on the 2026 UN Water Conference themes; petition to EPA to designate solar panels as universal waste; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Notice of Objection and Request for Board of Review in relation to the Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; Basel Convention implementing legislation; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; Clean Water and Drinking Water State Revolving Funds (SRFs); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); Water and Resilience Provisions (IIJA, P.L. 117-58); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); prioritizing new rulemaking to repair the 2024 Safer Communities by Chemical Accident Prevention: Risk Management Program Rule; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" (P.L. 119-2); reauthorization of the Drinking Water and Wastewater Infrastructure Act (P.L. 117-58, Title XII, Div. E); implementation of the Flood Level Observation, Operations, and Decision Support Act (P.L. 117‑316); implementation of the Safe Drinking Water Act (P.L. 93‑523); water sector workforce development initiatives; rural community water assistance programs; funding and authorization of Harbor Maintenance Trust Fund

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act; California Clean Air Act Waivers; Corporate Average Fuel Economy Standards;

Client expense: $1,160,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Plastic Waste / Advanced Recycling; PFAS; CFATS Reauthorization; State Polluter Pays Retroactive Penalty provisions and related issues; TSCA Reform; Endangered Species Act Reauthorization/Reform; The Hazardous Organic National Emission Standards for Hazardous Air Pollutants (HON Rule) H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act

Client expense: $1,160,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

ETO Bill (not introduced yet) Toxic Substances Control Act (no bill number) H.R. 7384 - Preventing Mass Casualties from Release of Hydrofluoric Acid at Refineries Act of 2026 Pesticides Registration Improvement Act H.R. 6938 - Commerce, Justice, Science; Energy and Water Development; and Interior and Environment Appropriations Act, 2026 H.R. 161 - New Source Review Permitting Improvement Act H.R. 4218 - CLEAR Act H.R. 6373 - Air Permitting Improvements to Protect National Security Act H.R. 6387 - FIRE Act H.R. 6398 - RED Tape Act H.R. 6409 - FENCES Act H.R. 4214 - Clean Air and Building Infrastructure Improvement Act S. 3049 - Fair Air Enforcement Act H.R. 6782/S.3529 - Public Health Air Quality Act of 2025 Clean Air Act (no bill number) Federal Power Act (no bill number) S.2015 - National Prescribed Fire Act of 2025

Client expense: $111,651 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2308/S. 1246, FEMA Independence Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3617, Securing Americas Critical Minerals Supply Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4357/S. 2260, Border Water Quality Restoration and Protection Act H.R. 4466, CIRCLE Act H.R. 4503, ePermit Act H.R. 4669, FEMA Act H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025 H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED) Tape Act H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act H.R. 7567, Farm, Food, and National Security Act of 2026 S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) Act of 2025 S. 623, No IRIS Act of 2025 S. 1323, Facilitating Increased Resilience, Environmental Weatherization and Lowered Liability Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3305, Curtailing Litigation Excess and Abuse Reform (CLEAR) Act of 2025 S. 3826, Modernizing Clean Air Permitting Act H.J. Res. 61/S.J. Res. 11, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J. Res. 87/S.J. Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J. Res. 88/S.J. Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J. Res. 89/S.J. Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" H.J. Res. 140, Superior National Forest Mineral Withdrawal CRA Resolution Discussion draft legislation To amend the Federal Water Pollution Control Act to exempt civil penalties for certain violations of such Act from the Federal Civil Penalties Inflation Adjustment Act of 1990, and for other purposes Discussion draft legislation to reform the Brownfields Program Draft legislation titled Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act - Discussion Draft Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation on PFAS Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Draft legislation relating to the reform of NEPA and other statutes as part of broader efforts to modernize federal environmental permitting Draft legislation titled the Recycled Materials Attribution Act (RMAA) Potential legislation regarding the reauthorization of surface transportation programs Potential legislation regarding TSCA reform Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S.3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 8030/S. 4134, Drought Relief Obtained Using Government Help Today Act of 2024 Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J. Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J. Res. 117/S.J. Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con. Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislation similar to S.Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Proposed rescission of the hazard index (HI) for select PFAS and extension of the compliance deadline for implementation of the National Primary Drinking Water Standard for PFOA and PFOS Proposed interim guidance for PFAS disposal and destruction Proposed Rule regarding Docket ID No. EPA-HQ-OLEM-2025-1707, Clean Water Act Hazardous Substance Facility Response Plans; Amendment Reconsideration, (91 Fed. Reg. 7,415-7,420, February 18, 2026) Proposed Rule, Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 Fed. Reg. 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Availability and Request for Comment on Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (86 Fed. Reg. 24,669-24,670, May 7, 2021) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216-72,312, October 19, 2023) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150-27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,610-10,616, February 25, 2025) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Notice; request for information (RFI), Office of Acquisition Policy, General Services Administration, Notice of Inquiry Regarding PFAS in Products; (89 Fed. Reg. 26,887-26,888, April 16, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Circularity for Secure and Sustainable Products and Materials: A Draft Strategic Framework Request for Information (EERE T 540.111-02, October 9, 2024) Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 68,894-68,896, August 28, 2024) Notice of Availability, Proposed High-Priority Substance Designations Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 60,420-60,424, July 25, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 (December 29, 2025) A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams (November 25, 2025) Comments on Proposed Revisions to the AIM Act Technology Transition Rule (Docket No. EPA-HQ-OAR-2025-0005) (November 21, 2025) Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272 (August 6, 2025) Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16 Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Notice ID: DODCMRMP05272025, Department of Defense Request for Information; Chemical and Material Risk Management Program (CMRMP) Toxic Substances Control Act (TSCA) Market Analysis (June 20, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat, (90 Fed. Reg. 52,607-52,615, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat, (90 Fed. Reg. 52,592- 52,599, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Interagency Cooperation Regulations, (90 Fed. Reg. 52,600-52,607, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants (90 Fed. Reg. 52,587-52,592, November 21, 2025) Various issues relating to regulatory permit streamlining; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; U.S.-Mexico water policy; energy security and its relationship to national security; phasing out of hydrofluorocarbons (HFCs); reauthorization of Water Resources Development Act (P.L. 118-272); National Environmental Policy Act permitting modernization and CEQ regulatory updates; Water Infrastructure Finance and Innovation Act expansion; Canadian plastics consultations; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; Congressional Review Act disapproval of regulations; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; implementation of the EU Methane Regulations; Endangered Species Act regulations and legislation; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; comments on the 2026 UN Water Conference themes; petition to EPA to designate solar panels as universal waste; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Notice of Objection and Request for Board of Review in relation to the Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; Basel Convention implementing legislation; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; Clean Water and Drinking Water State Revolving Funds (SRFs); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); Water and Resilience Provisions (IIJA, P.L. 117-58); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); prioritizing new rulemaking to repair the 2024 Safer Communities by Chemical Accident Prevention: Risk Management Program Rule; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" (P.L. 119-2); reauthorization of the Drinking Water and Wastewater Infrastructure Act (P.L. 117-58, Title XII, Div. E); implementation of the Flood Level Observation, Operations, and Decision Support Act (P.L. 117‑316); implementation of the Safe Drinking Water Act (P.L. 93‑523); water sector workforce development initiatives; rural community water assistance programs; funding and authorization of Harbor Maintenance Trust Fund

Client expense: $19,750,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

Oil and Natural Gas Sector: Emissions Standards for New, Reconstructed, and Modified Sources Review (EPA-HQ-OAR-2021-0317). Implementation Plan for the 2015 Ozone National Ambient Air Quality Standards (EPA-HQ-OAR-2021-0668; FRL 8670-02-OAR). Request for Information - Inflation Reduction Act Provisions for the Office of Air and Radiation Implementation (EPA-HQ-OAR-2022-0875; EPA-HQ-OAR-2022-0878). Federal policy relating to the role of natural gas infrastructure in achieving climate goals, including measures to promote innovation and investment in hydrogen, renewable natural gas and carbon capture, utilization, and storage. Federal policy relating to reducing methane emissions. H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act (provisions relating to the interstate natural gas pipeline sector). H.R. 1, One Big Beautiful Bill Act (provisions relating to the interstate natural gas pipeline sector). H.R. 161, H.R. 161, New Source Review (NSR) Permitting Improvement Act (provisions relating to the interstate natural gas pipeline sector). H.R. 4218, Clean Air and Economic Advancement Reform Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations Act (provisions relating to the interstate natural gas pipeline sector). H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability Act (provisions relating to the interstate natural gas pipeline sector).

Client expense: $326,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Urged EPA to extend Clean Water Act 401 Permit Rule Revision timeline, and opposed the rules rollback. Opposed the EPAs proposed revisions to its December 2024 final risk evaluation for formaldehyde (the Revised Risk Evaluation) Urged EPA to extend the comment period for and opposed its Common Sense Approach to Chemical Accident Prevention proposed rule. Urged the House of Representatives to reject the House Energy and Commerce committees discussion draft bill to amend the Toxic Substances Control Act. Opposed the Senate Republicans discussion draft bill titled Toxic Substances Control Act (TSCA) Fee Reauthorization and Improvement Act of 2026. Opposed H.R.1918/S.897, the Farewell to Foam Act Opposed EPA's rollback of the Clean Water Act's Waters of the United States definition Opposed EPAs decision to no longer quantify health effects of PM2.5 and ozone pollution when undertaking the cost-benefit analysis in Clean Air Act standards. Opposed H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Opposed H.R. 4218, the Clean Air and Economic Advancement Reform (CLEAR) Act Opposed H.R. 6387, the Fire Improvement and Reforming Exceptional Events (FIRE) Act Opposed H.R. 4214, the Clean Air and Building Infrastructure Improvement Act Opposed H.R. 161, the New Source Review Permitting Improvement Act Opposed H.R. 6373, the Air Permitting Improvements to Protect National Security Act Opposed H.R. 6398, the Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act Opposed the EPAs anticipated rollback of the 2024 Legacy Coal Combustion Residuals (CCR) Surface Impoundments and CCR Management Units Rule.

Client expense: $200,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

EPA Effluent Limitation Guidelines for Steam Electric Generating Units H.R. 3898, The Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, All Titles H.R. 3751, Reliable Grid Act, All Titles H.R. 161, New Source Review Permitting Improvement Act, All Titles H.R. 4218, Clean Air and Economic Advancement Reform (CLEAR) Act, All Titles H.R. 4214, Clean Air and Building Infrastructure Improvement Act, All Titles National Emission Standards for Hazardous Air Pollutants for Copper Smelter H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act, All Titles H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act, All Titles H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025, All Titles H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act, All Titles

Client expense: $720,000 · Firm income: Not reported

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

Lobbied in response to the U.S. Environmental Protection Agency's Integrated Iron & Steel Risk and Technology Review, EPA's Taconite Iron Ore Processing Source Category rule, EPA's National Emission Standards for Hazardous Air Pollutants for Coke Ovens, and EPA's National Emission Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Technology Review. Lobbied in support of Clean Air Act (CAA) Reform Legislation: H.R. 4218, the Clean Air and Economic Advancement Reform (CLEAR) Act, to allow technological and economic feasibility factors to be used by EPA for air quality standard decisions, as well as to extend the NAAQS review cycle from five years to 10 years. H.R.6387, the Fire Improvement and Reforming Exceptional Events (FIRE) Act, to appropriately permit air emissions resulting from exceptional events to be excluded from the NAAQS attainment designations. H.R.6409, the Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act, to similarly clarify that emissions emanating from outside of the U.S. can be excluded from designation decisions. H.R.4214, the Clean Air and Building Infrastructure Improvement Act, to amend the CAA to ensure regulated facilities have EPAs full implementation guidance prior to having to meet final NAAQS standards. H.R.161, the New Source Review Permitting Improvement Act, to clarify that modifications to existing facilities trigger New Source Review (NSR) permitting requirements only when the sources maximum achievable hourly emission rate is increased.

Client expense: $640,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Lobbied in response to the U.S. Environmental Protection Agency's Integrated Iron & Steel Risk and Technology Review, EPA's Taconite Iron Ore Processing Source Category rule, EPA's National Emission Standards for Hazardous Air Pollutants for Coke Ovens, and EPA's National Emission Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Technology Review. Lobbied in support of Clean Air Act (CAA) Reform Legislation: H.R. 4218, the Clean Air and Economic Advancement Reform (CLEAR) Act, to allow technological and economic feasibility factors to be used by EPA for air quality standard decisions, as well as to extend the NAAQS review cycle from five years to 10 years. H.R.6387, the Fire Improvement and Reforming Exceptional Events (FIRE) Act, to appropriately permit air emissions resulting from exceptional events to be excluded from the NAAQS attainment designations. H.R.6409, the Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act, to similarly clarify that emissions emanating from outside of the U.S. can be excluded from designation decisions. H.R.4214, the Clean Air and Building Infrastructure Improvement Act, to amend the CAA to ensure regulated facilities have EPAs full implementation guidance prior to having to meet final NAAQS standards. H.R.161, the New Source Review Permitting Improvement Act, to clarify that modifications to existing facilities trigger New Source Review (NSR) permitting requirements only when the sources maximum achievable hourly emission rate is increased.

Client expense: $640,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

HR 3898 PERMIT Act; HR 4218 Clean Air and Economic Advancement Reform Act; HR 4776 SPEED Act; HR 5966 Ohio River Restoration Program Act; HR 6387 Fire Improvement and Reforming Exceptional Events Act; HR 6398 Reducing and Eliminating Duplicative Environmental Regulations Act; HR 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability Act; draft legislation regarding reforms to CO2 storage; draft legislation regarding treatment of PFAS; draft legislation to improve methane monitoring and coordination among agencies; draft legislation to improve the equivalency of indistinguishable chemicals under TSCA; legislative efforts related to reauthorizing the Toxic Substances Control Act; 81 Fed. Reg. 35823 Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources; 86 Fed. Reg. 63110 Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review; 89 Fed. Reg. 16202 Reconsideration of the National Ambient Air Quality Standards for Particulate Matter; 90 Fed. Reg. 44591 Reconsideration of the Greenhouse Gas Reporting Program; 90 Fed. Reg. 52498 Updated Definition of "Waters of the United States"; efforts related to US equivalency for EU methane regulation; regulatory efforts related to Toxic Substances Control Act (TSCA) implementation for nomenclature purposes

Client expense: $1,910,000 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), White House Office

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling HR 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act HR 4218, Clean Air and Economic Advancement Reform (CLEAR) Act HR 4214, Clean Air and Building Infrastructure Improvement Act HR 161, New Source Review Permitting Improvement Act HR 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) HR 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act HR 6373, Air Permitting Improvements to Protect National Security Act HR 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act

Client expense: $580,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 3616, Reliable Power Act H.R. 1047, GRID Power Act H.R.2986 Expediting Generator Interconnection Procedures Act of 2025 H.R. 5600 Speed and Reliability Act of 2025 H.R. 4218, Clean Air and Economic Advancement Reform (CLEAR) Act (Rep. Carter) S. _____ Senate Democratic Discussion Draft Transmission Bill (Padilla) H.R. 7977 - Energy Bills Relief Act H.R. 2703 - Advancing GETs Act

Client expense: $70,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

AI and copyright issues. H.R.4218 - CLEAR Act. H.R.7209/S.2455 - TRAIN Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, Office of Science & Technology Policy (OSTP), SENATE, White House Office

H.R. 3898; Promoting Efficient Review for Modern Infrastructure Today Act or the PERMIT Act - provisions related to streamlined permitting activities under the Clean Water Act for benefit of infrastructure buildout. H.R. 6373; Air Permitting Improvements to Protect National Security Act of 2025 - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 6398; RED Tape Act, - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 2072; To require the Federal Energy Regulatory Commission to extend the time period during which licensees are required to commence construction of certain hydropower projects - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 6409; FENCES Act - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 4218; CLEAR Act - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 6387; FIRE Act - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 4214; Clean Air and Building infrastructure Improvement Act - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. H.R. 161; New Source Review Permitting Act - provisions related to the benefits of streamlined air permitting process for buildout of essential infrastructure energy components. Issues related to the NHTSA Corporate Average Fuel Economy standards for the benefits of consumers and vehicle-end pricing. Issues related to the Clean Air Act for purposes on the benefits of predictability in permitting.

Client expense: $700,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Clean Air Act; National Ambient Air Quality Standards; National Emissions Standards for Hazardous Air Pollutants; Resource Conservation and Recovery Act; Carbon Capture, Utilization, Transmission, and Storage; Permitting Reform; New Source Review Permitting Act (H.R. 161); Resilience; Alternative Fuels; Alternative Fuels Non Hazardous Waste Rule; Coal Combustion Residuals; Implementation of the Inflation Reduction Act (P.L. 117-116); Implementation of the Infrastructure Investment and Jobs Act (P.L. 117-58); IMPACT Act (HR 1534); Concrete and Asphalt Innovation Act (S. 1067); Portland Cement National Emissions Standards for Hazardous Air Pollutants; One, Big, Beautiful Bill Act (H.R. 1); Coal Ash for Infrastructure Act (H.R. 4875); SPEED Act (H.R. 4776); Reauthorization of EPA Water Infrastructure Programs; H.R.4214: Clean Air and Building Infrastructure Improvement Act; H.R.4218: Clean Air and Economic Advancement Reform (CLEAR) Act; H.R.6409: Foreign Emissions & Nonattainment Clarification for Economic Stability(FENCES) Act; H.R.6398: Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R.6387: Fire Improvement and Reforming Exceptional Events (FIRE) Act; Executive Order - Seeking Federal Recognition of Cement as a Critical National Security Material

Client expense: $360,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 4776 ; Standardizing permitting and expediting economic development Act (SPEED); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act

Client expense: $1,600,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Plastic Waste / Advanced Recycling; PFAS; CFATS Reauthorization; State Polluter Pays Retroactive Penalty provisions and related issues; TSCA Reform; Endangered Species Act Reauthorization/Reform; The Hazardous Organic National Emission Standards for Hazardous Air Pollutants (HON Rule) H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 4776 Standardizing permitting and expediting economic development Act (SPEED); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act

Client expense: $1,600,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling Clean Competition Act of 2025 S. 1863, the PROVE IT Act S. 1325, the Foreign Pollution Fee Act HR 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act HR 4218, Clean Air and Economic Advancement Reform (CLEAR) Act HR 4214, Clean Air and Building Infrastructure Improvement Act HR 161, New Source Review Permitting Improvement Act HR 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) HR 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act HR 6373, Air Permitting Improvements to Protect National Security Act HR 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act

Client expense: $810,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.3529/H.R. 6782 Public Health Air Quality Act S.3049 Fair Act Enforcement Act H.R. 6409 FENCES Act H.R. 4218 CLEAR Act H.R. 6387 FIRE Act H.R. 4214 Clean Air and Building Infrastructure Improvement Act H.R. 161 New Source Review Permitting Improvement Act H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act Recycling Technology Innovation Act - No bill number yet

Client expense: $107,772 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

EPA Effluent Limitation Guidelines for Steam Electric Generating Units H.R. 3898, The Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, All Titles H.R. 3870, COAL POWER Act, All Titles H.R. 3751, Reliable Grid Act, All Titles H.R. 2288, Common Sense Air Regulations Act, All Titles H.R. 1651, To nullify the final rule issued by the Environmental Protection Agency relating to "New Source Performance Standards for Greenhouse Gas Emissions From New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions From Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule, All Titles Compensatory Mitigation H.R. 161, New Source Review Permitting Improvement Act, All Titles H.R. 4218, Clean Air and Economic Advancement Reform (CLEAR) Act, All Titles H.R. 4214, Clean Air and Building Infrastructure Improvement Act, All Titles National Emission Standards for Hazardous Air Pollutants for Copper Smelter H.J.Res.79, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act" H.R. 3843, Baseload Reliability Power Act, All Titles H.R. 3143, State Planning for Reliability Affordability Act, All Titles H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act, All Titles H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act, All Titles H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025, All Titles H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act, All Titles

Client expense: $640,000 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

H.R. 3616, Reliable Power Act H.R. 1047, GRID Power Act H.R. 3632, Power Plant Reliability Act of 2025 H.R.3143 State Planning for Reliability and Affordability Act H.R.3657 Hydropower Relicensing Transparency Act H.R.3062 Promoting Cross-Border Energy Infrastructure Act H.R.2986 Expediting Generator Interconnection Procedures Act of 2025 H.R. 5600 Speed and Reliability Act of 2025 H.R. 4218, Clean Air and Economic Advancement Reform (CLEAR) Act (Rep. Carter)

Client expense: $70,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 346, Preserving Choice in Vehicle Purchases Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2308/S. 1246, FEMA Independence Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3548, Infrastructure Expansion Act H.R. 3699, Energy Choice Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4357/S. 2260, Border Water Quality Restoration and Protection Act H.R. 4466, CIRCLE Act H.R. 4503, ePermit Act H.R. 4669, FEMA Act H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act H.R. 6373, Air Permitting Improvements to Protect National Security Act of 2025 H.R. 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act H.R. 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED) Tape Act H.R. 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) S. 623, No IRIS Act of 2025 S. 1323, Facilitating Increased Resilience, Environmental Weatherization and Lowered Liability Act S. 2296, National Defense Authorization Act for Fiscal Year 2026 S. 3305, Curtailing Litigation Excess and Abuse Reform (CLEAR) Act of 2025 S. 3826, Modernizing Clean Air Permitting Act H.J.Res. 61/S.J.Res. 11 - Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J.Res. 87/S.J.Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J.Res. 88/S.J.Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J.Res. 89/S.J.Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" Discussion draft titled Clean Air and Building Infrastructure Improvement Act Discussion draft titled Clean Air and Economic Advancement Reform Act Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation titled the FEMA Act Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Draft legislation relating to the reform of NEPA and other statutes as part of broader efforts to modernize federal environmental permitting Draft legislation titled the Recycled Materials Attribution Act (RMAA) Potential legislation regarding the reauthorization of surface transportation programs Potential legislation regarding TSCA reform Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J.Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J.Res. 117/S.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con.Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislation similar to S.Con.Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 FR 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Availability and Request for Comment on Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (86 Fed. Reg. 24,669-24,670, May 7, 2021) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150-27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,610-10,616, February 25, 2025) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Proposed Rule regarding Revised Definition of Waters of the United States (86 Fed. Reg. 69,372-69,450, December 7, 2021) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216-72,312, October 19, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Notice; request for information (RFI), Office of Acquisition Policy, General Services Administration, Notice of Inquiry Regarding PFAS in Products; (89 Fed. Reg. 26,887-26,888, April 16, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Circularity for Secure and Sustainable Products and Materials: A Draft Strategic Framework Request for Information (EERE T 540.111-02, October 9, 2024) Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 68,894-68,896, August 28, 2024) Notice of Availability, Proposed High-Priority Substance Designations Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 60,420-60,424, July 25, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Extension Request for Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (89 Fed. Reg. 105,041-105,043, December 26, 2024) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Extension request to Methods Update Rule (MUR), December 27, 2024; 21 CFR Part 730 Docket Number FDA-2023-N-4225 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 (December 29, 2025) A Consultation Document on Phase 1 of the Risk Management of PFAS, Excluding Fluoropolymers: Prohibition of the Use of PFAS, not Currently Regulated, in Firefighting Foams (November 25, 2025) Comments on Proposed Revisions to the AIM Act Technology Transition Rule (Docket No. EPA-HQ-OAR-2025-0005) (November 21, 2025) Comments on Section 401 State Water Quality Certification Open Docket; Docket ID No. EPA-HQ-OW-2025-0272 (August 6, 2025) Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16 Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Notice ID: DODCMRMP05272025, Department of Defense Request for Information; Chemical and Material Risk Management Program (CMRMP) Toxic Substances Control Act (TSCA) Market Analysis (June 20, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Listing Endangered and Threatened Species and Designating Critical Habitat, (90 Fed. Reg. 52,607-52,615, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations for Designating Critical Habitat, (90 Fed. Reg. 52,592-52,599, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Interagency Cooperation Regulations, (90 Fed. Reg. 52,600-52,607, November 21, 2025) Proposed Rule, Endangered and Threatened Wildlife and Plants; Regulations Pertaining to Endangered and Threatened Wildlife and Plants (90 Fed. Reg. 52,587- 52,592, November 21, 2025) Proposed Rule, Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (P.L. 114-182); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the STORM Act (P.L. 116-284); implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; implementation of the Disaster Recovery Reform Act of 2018 (P.L. 115-254); U.S.-Mexico water policy; energy security and its relationship to national security; diversifying energy sources including issues related to the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; corporate average fuel economy (CAFE) standards; federal flood risk management standard; sea level rise and erosion associated with climate change; phasing out of hydrofluorocarbons (HFCs); Nationally Determined Contributions (NDCs) under the Paris Climate Accords; DOE Review of Bulk Power Sector Supply Chain Executive Order; environmental, social, and governance (ESG) enforcement; Canadian plastics consultations; deployment of Smart Water Infrastructure Technology; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; FERC certification of new interstate gas facilities; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; proposed risk management consultation on PFAS; reconsideration of the Greenhouse Gas Reporting Program, 90 Fed. Reg. 44,591; Congressional Review Act disapproval of regulations; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; implementation of the EU Methane Regulations; Endangered Species Act regulations; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; comments on the 2026 UN Water Conference themes; petition to EPA to designate solar panels as universal waste; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Notice of Objection and Request for Board of Review in relation to the Order Adding a Toxic Substance to Part 2 of Schedule 1 to the Canadian Environmental Protection Act, 1999; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; Basel Convention implementing legislation; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; EPAs proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs); Clean Water and Drinking Water State Revolving Funds (SRFs); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); Water and Resilience Provisions (IIJA, P.L. 117-58); Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities - Docket No. EPA-HQ-OLEM-2023-0644; Climate Reporting (Related to Final Rule, SEC; The Enhancement and Standardization of Climate-Related Disclosures for Investors, (89 Fed. Reg. 21,668-21,921, March 28, 2024)); Clean Water Act Hazardous Substance Facility Response Plans [EPA-HQ-OLEM-2021-0585; FRL-7881-01-OLEM] RIN 2050-AH17; Land and Water Conservation Fund (LWCF) State and Local Assistance Formula Funding Program; Proposed Organic Chemicals, Plastics and Synthetic Fibers Effluent Limitation Guidelines (ELG); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); prioritizing new rulemaking to repair the 2024 Safer Communities by Chemical Accident Prevention: Risk Management Program Rule; funding for National Oceanic and Atmospheric Administration (NOAA); Federal Communication Commissions proposed rule, Modernizing the Commissions National Environmental Policy Act Rules; Final Environmental Impact Statement (FEIS) prepared by the U.S. Forest Service (USFS) for the Resolution Copper project; repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" (P.L. No: 119-2); United States-Brazil Critical Minerals Cooperation

Client expense: $17,960,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

HR 3898 PERMIT Act; HR 4218 Clean Air and Economic Advancement Reform Act; HR 4776 SPEED Act; HR 4880 Primacy Certainty Act of 2025; HR 6387 Fire Improvement and Reforming Exceptional Events Act; HR 6398 Reducing and Eliminating Duplicative Environmental Regulations Act; HR 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability Act; S.J. Res. 76 A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Extension of Deadlines in Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review Final Rule"; draft legislation regarding reforms to CO2 storage; draft legislation regarding treatment of PFAS; draft legislation to repeal the EPA's Waste Emissions Charge; legislative efforts related to reauthorizing the Toxic Substances Control Act; RIN 2060-AW63 Interstate Transport Plan Review for the 2015 Ozone NAAQS - Phase 1; RIN 2070-AL29 Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under the Toxic Substances Control Act (TSCA); Revision to Regulation; 81 Fed. Reg. 35823 Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources; 82 Fed. Reg. 27645 Oil and Natural Gas Sector: Emission Standards for New, Reconstructed, and Modified Sources: Three Month Stay of Certain Requirements; 83 Fed. Reg. 13745 Project Emissions Accounting Under the New Source Review Preconstruction Permitting Program; 85 Fed. Reg. 21849 Review of the Ozone National Ambient Air Quality Standards; 85 Fed. Reg. 87256 Review of the Ozone National Ambient Air Quality Standards; 88 Fed. Reg. 50282 Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems; 88 Fed. Reg. 5558 Reconsideration of the National Ambient Air Quality Standards for Particulate Matter; 89 Fed. Reg. 16202 Reconsideration of the National Ambient Air Quality Standards for Particulate Matter; 90 Fed. Reg. 44591 Reconsideration of the Greenhouse Gas Reporting Program; 90 Fed. Reg. 45367 Reconsideration of the Greenhouse Gas Reporting Program; 90 Fed. Reg. 52498 Updated Definition of "Waters of the United States"; 90 Fed. Reg. 5794 Reconsideration of Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review; efforts related to NAAQS implementation interpretations of modeling, monitoring, and exceptional events treatment.

Client expense: $1,920,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office

H.R. 245, New Source Review Permitting Improvement Act H.R. 278, the BROADBAND Leadership Act H.R. 346, Preserving Choice in Vehicle Purchases Act H.R. 471/S. 1462, Fix Our Forests Act of 2025 H.R. 640/S. 615, Chemical Tax Repeal Act H.R. 804, Rural Small Business Resilience Act of 2025 H.R. 2145, Recycling Infrastructure and Accessibility Act of 2025 H.R. 2288, Common Sense Air Regulations Act H.R. 2709, Save our Sequoias Act H.R. 2940, Advancing Water Reuse Act H.R. 3548, Infrastructure Expansion Act H.R. 3862, Clean Water SRF Parity Act H.R. 3898, Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act H.R. 3899, Clarifying Federal General Permits Act H.R. 3900, Water Quality Technology Availability Act H.R. 3927, Nationwide Permitting Improvement Act H.R. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 4109, Recycling and Composting Accountability Act H.R. 4214, Clean Air and Building Infrastructure Improvement Act H.R. 4218, Clean Air and Economic Advancement Reform Act H.R. 4466, the CIRCLE Act H.R. 4503, ePermit Act H.R. 4669, the FEMA Act H.R. 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act S. 351, Strategies to Eliminate Water and Accelerate Recycling Development (STEWARD) S. 623, No IRIS Act of 2025 S. 2296, FY 2026 National Defense Authorization Act S. 3826, Modernizing Clean Air Permitting Act H.J.Res. 61/S.J.Res. 11, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "National Emission Standards for Hazardous Air Pollutants: Rubber Tire Manufacturing H.J. Res. 87/S.J. Res. 46, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Heavy-Duty Vehicle and Engine Emission Warranty and Maintenance Provisions; Advanced Clean Trucks; Zero Emission Airport Shuttle; Zero-Emission Power Train Certification; Waiver of Preemption; Notice of Decision" H.J. Res. 88/S.J. Res. 45, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine Pollution Control Standards; Advanced Clean Cars II; Waiver of Preemption; Notice of Decision" H.J. Res. 89/S.J. Res. 47, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "California State Motor Vehicle and Engine and Nonroad Engine Pollution Control Standards; The 'Omnibus' Low NOx Regulation; Waiver of Preemption; Notice of Decision" Discussion draft titled Clean Air and Building Infrastructure Improvement Act Discussion draft titled Clean Air and Economic Advancement Reform Act Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation titled the FEMA Act Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Potential legislation regarding TSCA reform Potential legislation to amend the Robert T. Stafford Disaster Relief and Emergency Assistance Act to require predisaster hazard mitigation assistance to be awarded during the fiscal year during which an application is submitted Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislative action similar to H.J. Res. 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Army, Corps of Engineers, Department of Defense and the Environmental Protection Agency relating to "Revised Definition of 'Waters of the United States'" Potential legislative action similar to H.J.Res. 117/S.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Reconsideration of the National Ambient Air Quality Standards for Particulate Matter" Potential legislative action similar to H.Con.Res. 34, expressing disapproval of the withdrawal by the Secretary of the Interior of approximately 225,504 acres of National Forest System lands in Cook, Lake, and Saint Louis Counties, Minnesota, from disposition under the United States mineral and geothermal leasing laws Potential legislation similar to S.Con.Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Potential resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Federal Good Neighbor Plan for the 2015 Ozone National Ambient Air Quality Standards; Notice on Remand of the Record of the Good Neighbor Plan to Respond to Certain Comments. Nomination of Aaron Szabo to be the Assistant Administrator of the Environmental Protection Agencys Office of Air and Radiation Nomination of Katherine Scarlett to be Chair of the White House Council on Environmental Quality Proposed Rule, Reconsideration of 2009 Endangerment Finding and Greenhouse Gas Vehicle Standards, (90 FR 36,288, EPA-HQ-OAR-2025-0194, August 1, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Availability and Request for Comment on Technical Support Document: Social Cost of Carbon, Methane, and Nitrous Oxide Interim Estimates Under Executive Order 13990 (86 Fed. Reg. 24,669-24,670, May 7, 2021) Proposed Rule on Phasedown of Hydrofluorocarbons: Establishing the Allowance Allocation and Trading Program under the American Innovation and Manufacturing Act (86 Fed. Reg. 27,150 - 27,223, May 19, 2021) Proposed Rule, Reconsideration of the 2020 National Emission Standards for Hazardous Air Pollutants: Miscellaneous Organic Chemical Manufacturing Residual Risk and Technology Review; Environmental Protection Agency (87 Fed. Reg. 6,466-6,473, February 4, 2022) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,610-10,616, February 25, 2025) Proposed Rule, Designation of Perfluorooctanoic Acid (PFOA) and Perfluorooctanesulfonic Acid (PFOS) as CERCLA Hazardous Substances (87 Fed. Reg. 54,415-54,442, September 6, 2022) Proposed Rule regarding Revised Definition of Waters of the United States (86 Fed. Reg. 69,372-69,450, December 7, 2021) Final Rule, Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (89 Fed. Reg. 16,202-16,406, March 6, 2024) Final Rule, Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (89 Fed. Reg. 17,622-17,692, March 11, 2024) TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of Data Availability and Request for Comment (87 Fed. Reg. 72,439-72,441, November 25, 2022) Proposed Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under Subsection (i) the American Innovation and Manufacturing Act of 2020 (87 Fed. Reg. 76,738-76,813, December 15, 2022) Proposed Rule, Federal Acquisition Regulatory Council; Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (87 Fed. Reg. 68,312-68,334, November 14, 2022) Final Rule, Environmental Protection Agency; Standards of Performance for New, Reconstructed, and Modified Sources and Emissions Guidelines for Existing Sources; Oil and Natural Gas Sector Climate Review (89 Fed. Reg. 16,820-17,227, March 8, 2024) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Proposed Rule, Bureau of Land Management: Conservation and Landscape Health (88 Fed. Reg. 19,583-19,604, April 3, 2023) Multi-Pollutant Emissions Standards for Model Years 2027 and Later Light-Duty and Medium-Duty Vehicles, (88 Fed. Reg. 29,184-29,446, May 5, 2023) Phasedown of Hydrofluorocarbons: Management of Certain Hydrofluorocarbons and Substitutes Under Subsection (h) of the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 72,216 - 72,312, October 19, 2023) New Source Performance Standards for Greenhouse Gas Emissions from New, Modified and Reconstructed Fossil Fuel-Fired Electric Generating Units: Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (88 Fed. Reg. 80,682-80,685, November 20, 2023) Proposed Rule, Revising Scope of the Mining Sector of Projects That Are Eligible for Coverage Under Title 41 of the Fixing America's Surface Transportation Act (88 Fed. Reg. 65,350-65,356, September 22, 2023) Proposed Rule, Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 15,967-15,968, February 8, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Notice; request for information (RFI), Office of Acquisition Policy, General Services Administration, Notice of Inquiry Regarding PFAS in Products; (89 Fed. Reg. 26,887-26,888, April 16, 2024) Final Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (89 Fed. Reg. 35,442-35,577, May 1, 2024) Proposed Rule, Addition of Certain Per- and Polyfluoroalkyl Substances (PFAS) to the Toxics Release Request for Information Inventory (TRI) (89 Fed. Reg. 81,776, October 8, 2024) Circularity for Secure and Sustainable Products and Materials: A Draft Strategic Framework Request for Information (EERE T 540.111-02, October 9, 2024) Public Engagement Webinars; Pre-Prioritization and Consideration of Existing Chemical Substances for Future Prioritization Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 68,894-68,896, August 28, 2024) Notice of Availability, Proposed High-Priority Substance Designations Under the Toxic Substances Control Act (TSCA) (89 Fed. Reg. 60,420-60,424, July 25, 2024) Final Rule, Negative Options Rule, (89 Fed. Reg. 90,476, November 11, 2024) Final Rule, Premerger Notification; Reporting and Waiting Period Requirements, (89 Fed. Reg. 89,216, November 12, 2024) Proposed Rule, Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act (TSCA), (40 CFR Part 702; EPA-HQ-OPPT-2025-0260; FRL-8529.1-01-OCSPP; RIN 2070-AL27) Extension Request for Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (89 Fed. Reg. 105,041-105,043, December 26, 2024) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Extension request to Methods Update Rule (MUR), December 27, 2024; 21 CFR Part 730 Docket Number FDA-2023-N-4225 Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) Notice of 2025 Draft List of Critical Minerals (90 Fed. Reg. 41,591 - 41,593, August 26, 2025) Preliminary Effluent Guidelines Program Plan 16 Proposed Toxics Release Inventory (TRI); Clarification of Toxic Chemicals Due to Automatic Additions of Per- and Polyfluoroalkyl Substances Under the National Defense Authorization Act (90 Fed. Reg. 5,795-5,798, January 17, 2025) Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (EPA-HQ-OW-2024-0454; FRL 12023-01-OW) (April 29, 2025) Request for Withdrawal and Comments of the Proposed National Pollutant Discharge Elimination System (NPDES) 2026 Issuance of the Multi-Sector General Permit (MSGP) for Stormwater Discharges Associated with Industrial Activity; EPA-HQ-OW-2024-0481 (May 19, 2025) Notice ID: DODCMRMP05272025, Department of Defense Request for Information; Chemical and Material Risk Management Program (CMRMP) Toxic Substances Control Act (TSCA) Market Analysis (June 20, 2025) Proposed Rule, Review of New Source Performance Standards for Stationary Combustion Turbines and Stationary Gas Turbines, (89 Fed. Reg. 101,306-101,356, December 13, 2024) Proposed Rule, National Emission Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating Units, (90 Fed. Reg. 25,535-25,546, June 17, 2025) Interim Final Rule, Removal of National Environmental Policy Act Implementing Regulations, (90 Fed. Reg. 10,611, February 25, 2025) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); implementation of the National Environmental Policy Act (P.L. 91-190); implementation of the Frank R. Lautenberg Chemical Safety for the 21st Century Act (P.L. 114-182); implementation and reforms of the Toxic Substances Control Act (P.L. 94-469); implementation of the American Innovation and Manufacturing (AIM) Act (P.L. 116-260, Div. S, section 103) including provision implementation of the laws Allocation Rule; implementation of the STORM Act (P.L. 116-284); implementation of the Comprehensive Environmental Response, Compensation, and Liability Act (CERLCA, P.L. 96-510), including private cleanup cost and designating Perfluorooctanoic acid (PFOA) and Perfluorooctane sulfonic acid (PFOS) under CERCLA; implementation of the Disaster Recovery Reform Act of 2018 (P.L. 115-254); funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.-Mexico water policy; energy security and its relationship to national security; diversifying energy sources including issues related to the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; corporate average fuel economy (CAFE) standards; federal flood risk management standard; sea level rise and erosion associated with climate change; phasing out of hydrofluorocarbons (HFCs); Nationally Determined Contributions (NDCs) under the Paris Climate Accords; DOE Review of Bulk Power Sector Supply Chain Executive Order; environmental, social, and governance (ESG) enforcement; deployment of Smart Water Infrastructure Technology; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; FERC certification of new interstate gas facilities; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; Congressional Review Act disapproval of regulations generally; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; Proposed rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) under interagency review by the Office of Management and Budget (OMB); U.S. Agency for International Development (USAID) Global Water Security Action Plan; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; Department of Treasury hydrogen production tax credit (45V) guidance; EU Methane Regulations; Endangered Species Act regulations; General Services Administration (GSA) Acquisition Policy Federal Advisory Committee (GAP FAC) report and letter regarding per- and polyfluoroalkyl (PFAS) substances; U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; Natural Capital Accounting guidance; Sustainable Aviation Fuels Blenders Tax Credit and CORSIA voluntary carbon markets; implementation and proposed changes to the Waters of the U.S.; comments on the 2026 UN Water Conference themes; petition to EPA to designate solar panels as universal waste; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; EPAs proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs); Clean Water and Drinking Water State Revolving Funds (SRFs); Water and Resilience Provisions (IIJA, P.L. 117-58); Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities - Docket No. EPA-HQ-OLEM-2023-0644; Climate Reporting (Related to Final Rule, SEC; The Enhancement and Standardization of Climate-Related Disclosures for Investors, (89 Fed. Reg. 21,668-21,921, March 28, 2024); Clean Water Act Hazardous Substance Facility Response Plans [EPA-HQ-OLEM-2021-0585; FRL-7881-01-OLEM] RIN 2050-AH17; Land and Water Conservation Fund (LWCF) State and Local Assistance Formula Funding Program; Proposed Organic Chemicals, Plastics and Synthetic Fibers Effluent Limitation Guidelines (ELG); inefficiencies and delays in the EPA's New Chemicals Program under Toxic Substances Control Act (P.L. 94-469); prioritizing new rulemaking to repair the 2024 Safer Communities by Chemical Accident Prevention: Risk Management Program Rule; funding for National Oceanic and Atmospheric Administration (NOAA); Federal Communication Commissions proposed rule, Modernizing the Commissions National Environmental Policy Act Rules; Final Environmental Impact Statement (FEIS) prepared by the U.S. Forest Service (USFS) for the Resolution Copper project; repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" (P.L. No: 119-2); United States-Brazil Critical Minerals Cooperation

Client expense: $13,650,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Army, Dept of (Corps of Engineers), Bureau of Reclamation, Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Oceanic & Atmospheric Administration (NOAA), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS), Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Trade Representative (USTR)

EPA Effluent Limitation Guidelines for Steam Electric Generating Units H.R. 3898, The Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, All Titles H.R. 3899, The Clarifying Federal General Permits Act, All Titles H.R. 3900, The Water Quality Technology Availability Act, All Titles H.R. 3928, The Improving Water Quality Certifications and American Energy Infrastructure Act, All Titles H.R. 3824, The Reducing Regulatory Burdens Act, All Titles H.R. 3927, The Nationwide Permitting Improvement Act, All Titles H.R. 3935, The Reducing Permitting Uncertainty Act, All Titles H.R. 3888, The Water Quality Criteria Development and Transparency Act, All Titles H.R. 3905, The Judicial Review Timeline Clarity Act, All Titles H.R. 3901, The Jurisdictional Determination Backlog Reduction Act, All Titles H.R. 3934, The Water Quality Standards Attainability Act, All Titles H.R. 3897, The Confidence in Clean Water Permits Act, All Titles H.R. 3870, COAL POWER Act, All Titles H.R. 3751, Reliable Grid Act, All Titles H.R. 4218, To amend the Clean Air Act to facilitate State implementation of national ambient air quality standards, and for other purposes, All Titles H.R. 2288, Common Sense Air Regulations Act, All Titles H.R. 4214, To require the Administrator of the Environmental Protection Agency to publish, concurrently with any final rule establishing or revising a national ambient air quality standard, regulations and guidance for implementing the standard, including information relating to submission and consideration of a preconstruction permit application under the new or revised standard, and for other purposes, All Titles H.R. 1651, To nullify the final rule issued by the Environmental Protection Agency relating to "New Source Performance Standards for Greenhouse Gas Emissions From New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions From Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule, All Titles Compensatory Mitigation H.R. 161, New Source Review Permitting Improvement Act, All Titles H.R. 4218, Clean Air Act State Implementation of National Ambient Air Quality Standards, All Titles H.R. 4214, Clean Air and Building Infrastructure Improvement Act, All Titles National Emission Standards for Hazardous Air Pollutants for Copper Smelter H.J.Res.79, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act" H.R. 3843, Baseload Reliability Power Act, All Titles H.R. 3143, State Planning for Reliability Affordability Act, All Titles

Client expense: $649,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

EPA Coal Power Plant Sector Rules H.R. 3898, The Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, All itles H.R. 3899, The Clarifying Federal General Permits Act, All Titles H.R. 3900, The Water Quality Technology Availability Act, All Titles H.R. 3928, The Improving Water Quality Certifications and American Energy Infrastructure Act, All Titles H.R. 3824, The Reducing Regulatory Burdens Act, All Titles H.R. 3927, The Nationwide Permitting Improvement Act, All Titles H.R. 3935, The Reducing Permitting Uncertainty Act, All Titles H.R. 3888, The Water Quality Criteria Development and Transparency Act, All Titles H.R. 3905, The Judicial Review Timeline Clarity Act, All Titles H.R. 3901, The Jurisdictional Determination Backlog Reduction Act, All Titles H.R. 3934, The Water Quality Standards Attainability Act, All Titles H.R. 3897, The Confidence in Clean Water Permits Act, All Titles H.R. 3870, COAL POWER Act, All Titles H.R. 3751, Reliable Grid Act, All Titles H.R. 4218, To amend the Clean Air Act to facilitate State implementation of national ambient air quality standards, and for other purposes, All Titles H.R. 2288, Common Sense Air Regulations Act, All Titles H.R. 4214, To require the Administrator of the Environmental Protection Agency to publish, concurrently with any final rule establishing or revising a national ambient air quality standard, regulations and guidance for implementing the standard, including information relating to submission and consideration of a preconstruction permit application under the new or revised standard, and for other purposes, All Titles H.R. 1651, To nullify the final rule issued by the Environmental Protection Agency relating to "New Source Performance Standards for Greenhouse Gas Emissions From New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions From Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule, All Titles Compensatory Mitigation H.R. 161, New Source Review Permitting Improvement Act, All Titles H.R. 4218, Clean Air Act State Implementation of National Ambient Air Quality Standards, All Titles H.R. 4214, Clean Air and Building Infrastructure Improvement Act, All Titles National Emission Standards for Hazardous Air Pollutants for Copper Smelters, All Titles H.J.Res.79, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act"

Client expense: $760,000 · Firm income: Not reported

Government targets: Energy, Dept of, Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

EPA Coal Power Plant Sector Rules H.R. 3898, The Promoting Efficient Review for Modern Infrastructure Today (PERMIT) Act, All itles H.R. 3899, The Clarifying Federal General Permits Act, All Titles H.R. 3900, The Water Quality Technology Availability Act, All Titles H.R. 3928, The Improving Water Quality Certifications and American Energy Infrastructure Act, All Titles H.R. 3824, The Reducing Regulatory Burdens Act, All Titles H.R. 3927, The Nationwide Permitting Improvement Act, All Titles H.R. 3935, The Reducing Permitting Uncertainty Act, All Titles H.R. 3888, The Water Quality Criteria Development and Transparency Act, All Titles H.R. 3905, The Judicial Review Timeline Clarity Act, All Titles H.R. 3901, The Jurisdictional Determination Backlog Reduction Act, All Titles H.R. 3934, The Water Quality Standards Attainability Act, All Titles H.R. 3897, The Confidence in Clean Water Permits Act, All Titles H.R. 3870, COAL POWER Act, All Titles H.R. 3751, Reliable Grid Act, All Titles H.R. 4218, To amend the Clean Air Act to facilitate State implementation of national ambient air quality standards, and for other purposes, All Titles H.R. 2288, Common Sense Air Regulations Act, All Titles H.R. 4214, To require the Administrator of the Environmental Protection Agency to publish, concurrently with any final rule establishing or revising a national ambient air quality standard, regulations and guidance for implementing the standard, including information relating to submission and consideration of a preconstruction permit application under the new or revised standard, and for other purposes, All Titles H.R. 1651, To nullify the final rule issued by the Environmental Protection Agency relating to "New Source Performance Standards for Greenhouse Gas Emissions From New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions From Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule, All Titles Compensatory Mitigation H.R. 161, New Source Review Permitting Improvement Act, All Titles H.R. 4218, Clean Air Act State Implementation of National Ambient Air Quality Standards, All Titles H.R. 4214, Clean Air and Building Infrastructure Improvement Act, All Titles National Emission Standards for Hazardous Air Pollutants for Copper Smelters, All Titles H.J.Res.79, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act"

Client expense: $76,000 · Firm income: Not reported

Government targets: Energy, Dept of, Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE