PFAS-Free Procurement Act of 2023

P.L. 117-58, Inflation Reduction Act; P.L. 117-169, Bipartisan Infrastructure Law; H.J. Res. 117, 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"; H.J. Res 123, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention"; H.J. Res. 161, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry"; H.R. 1, Lower Energy Cost Act including provisions on chemical reviews; H.R. 815, Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes; H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes. Climate policy/carbon emissions reduction; H.R. 1158, Elimination of Future Technology Delays Act of 2023; H.R. 1517, Relief for Farmers Hit with PFAS Act; H.R. 1633, Reducing Accidents In Locomotives (RAIL) Act; H.R. 1674, 1674 Railway Safety Act of 2023; H.R. 2670, National Defense Authorization Act for FY 2024 (including chemical management provisions Subtitle C, Sections 331-336; H.R. 2811, Limit, Save, Grow Act of 2023; H.R. 3716, SPUR Act; H.R. 3746, Fiscal Responsibility Act; H.R. 3935, Securing Growth and Robust Leadership in American Aviation Act; H.R. 3938, Build It In America Act; H.R. 3953, Debt Ceiling Reform Act; H.R. 4040, Recycling and Composting Accountability Act; H.R. 4194, Protecting Communities from Plastics Act of 2024; H.R. 4310, Youth Poisoning Protection Act; H.R. 4366, Consolidated Appropriations Act, 2024; H.R. 4470, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; H.R. 4561, Reducing Waste in National Parks Act; H.R. 4821, Department of the Interior, Environment, and Related Agencies Appropriations Act 2024; including 518; H.R. 4893, Scientific Integrity Act; H.R. 5134, Biomanufacturing and Jobs Act; H.R. 5260, PFAS Free Military Purchasing Act; H.R. 5860, Continuing Appropriations Act, 2024 and Other Extensions Act; H.R. 6053, Break Free from Plastic Pollution Act of 2023; H.R. 6159, Recycling Infrastructure and Accessibility Act; H.R. 6363, Further Continuing Appropriation and Other Extensions Act, 2024; H.R. 6454 Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 6654, Farewell to Foam Act of 2023; H.R. 6805, PFAS Action Act of 2023; H.R. 7194, PFAS Accountability Act; H.R 7284, No IRIS Act; H.R. 7775, PFAS-Free Procurement Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8034, Israel Security Supplemental Appropriations Act, 2024; H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025; H.R. 8092, Protecting Communities from Plastics Act of 2024; H.R. 8204, Regulatory Early Notice and Engagement Act (RENEA) of 2024; H.R. 8467, Farm, Food, and National Security Act of 2024; H.R. 8774, Department of Defense Appropriations Act, 2024; H.R. 8996, Railroad Safety Enhancement Act of 2024; H.R. 8997, Energy and Water Development and Related Agencies appropriations Act, 2025; H.R. 8998, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025; H.R. 9676, Accelerating a Circular Economy for Plastics and Recycling Innovation Act of 2024; H. Rept. 118-581, DEPARTMENT OF THE INTERIOR, ENVIRONMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2025; H.R. 9026, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2025; S.J. Res. 100, 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 "New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry."; S. 576, Railway Safety Act of 2023; S. 747, Relief for Farmers Hit with PFAS Act; S. 844, Assistance for Local Heroes During Train Crises Act; S. 866, American Innovation and Jobs Act; S. 1189, Recycling Infrastructure and Accessibility Act; S. 1194, Recycling and Composting Accountability Act; S. 1195, Chemical Tax Repeal Act; S. 1427, Agriculture PFAS Liability Protection Act of 2023; S. 1429, Resource Management PFAS Liability Protection Act of 2023; S. 1430, Water Systems PFAS Liability Protection Act of 2023; S. 1432, Fire Suppression PFAS Liability Protection Act of 2023; S. 1433, Airports PFAS Liability Protection Act of 2023; S. 1449, RESTART Act; S. 1456, SPUR Act; S. 1863, PROVE IT Act; S. 1882, Debt Ceiling Reform Act; S. 1939, FAA Reauthorization Act of 2023; S. 2178, A bill to extend the Chemical Facility Anti-Terrorism Standards Program of the Department of Homeland Security, and for other purposes; S. 2226, National Defense Authorization Act for FY 2024, including Title III, Section 321; S. 2233, Youth Poisoning Protection Act; S. 2283, PFAS-Free Procurement Act of 2023; S. 2337, Plastic Pellet Free Waters Act; S. 2499, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; S. 2728, Reducing Waste in National Parks Act; S. 2844, REDUCE Act of 2023; S. 3127, Break Free from Plastic Pollution Act of 2023; S. 3198, Foreign Pollution Fee Act; S. 3512, The Truth in Labeling Act of 2024; S. 3719, Sound Science for Farmers Act; S. 3724, No IRIS Act; S. 3725, PFAS Accountability Act; S. 4194, Protecting Communities form Plastics Act of 2024; S. 4638, National Defense Authorization Act for Fiscal Year 2025; S. 4795, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2025; S. 4802, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025; S. 4884, Fighting Fibers Act of 2024; S. 4921, Department of Defense Appropriations Act, 2025; FY2024 Department of Interior, Environment, and Related Agencies Appropriations; FY2024 National Defense Authorization Act, use of advanced materials in infrastructure; FY2025 National Defense Authorization, including use of advanced materials in infrastructure; FY2025 Agriculture Rural Development, FDA, and Related Agencies; FY2025 Commerce, Justice, Science, and Related Agencies; FY2025 Department of Energy Appropriations; FY2025 THUD and Energy and Water Appropriations; Unintroduced FY2024 DOE Appropriations; Unintroduced Legislation - 5 Actions for Sustainable Change; Unintroduced Legislation on Agriculture Policies (Farm Bill) on Chemicals Management Issues; Unintroduced Save Our Seas 3.0; Unintroduced Legislation regarding actions for sustainable change; Unintroduced PFAS legislation; Unintroduced Plastic Waste Reduction and Recycling Research Act; Unintroduced Protecting Communities From Plastics Act; Unintroduced Legislation dealing with plastic pellet management and microplastics; Unintroduced Regulatory Early Notice and Engagement Act; Unintroduced Senate Energy and Water Development Appropriations Act; Unintroduced House Science Committee Plastic Waste and Recycling Research Legislation; Unintroduced Plastics Health Research Act; 86 Fed. Reg. 50296, Advance Notice of Proposed Rulemaking for Pyrolysis and Gasification; 87 Fed. Reg. 53556, Accidental Release Prevention Requirements: Risk Management Program Under the Clean Air Act; Safer Communities by Chemical Accident Prevention; 88 Fed. Reg. 27502, Draft National Strategy to Prevent Plastic Pollution; 88 Fed. Reg. 39804, SNUR on Certain Chemical Substances (23-2.5e); Automotive Plastics; Basel Convention and Plastic Waste; Biobased Products Procurement and Labeling; Chemical Facilities Anti-Terrorism Standards; Chemicals Management; Climate policy/carbon emissions reduction; Oversight of Department of Energy and Environmental Protection Agency on Chemicals Regulation; Ethylene Oxide; Extended Producer Responsibility; Formaldehyde; Food Contact Regulation for recycled materials; Fifth Session of the Intergovernmental Negotiating Committee to develop a legally binding instrument for plastic pollution; FTC Green Guides 87 Fed. Reg. 77766; Implementation of the Superfund Tax on Chemicals; IRIS appropriations; Microplastics; National Plastics Strategy; Permitting reform; PFAS; PRIA Implementation; Recycling; Proposed SNUR for Fuels Made Using Plastic Waste Based Feedstocks; TSCA Implementation including new chemicals, 1,3-butadiene, formaldehyde, methylene chloride; United Nations Plastics Agreement and Cumulative Impact Assessments Negotiations

Client expense: $5,830,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Trade Commission (FTC), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Security Council (NSC), Office of Management & Budget (OMB), SENATE, State, Dept of (DOS)

H.R. 886, Save our Seas Amendments Act 2.0 H.R. 1152, Water Quality Certification and Energy Project Improvement Act of 2023 H.R. 1435, Preserving Choice in Vehicle Purchases Act H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 H.R. 2670, FY 2024 National Defense Authorization Act H.R. 2925/S. 1281, Mining Regulatory Clarity Act H.R. 2989, Save Our Sequoias Act of 2023 H.R. 3195, Superior National Forest Restoration Act H.R. 3397, Western Economic Security Today Act of 2024 H.R. 4288, Agricultural Labeling Uniformity Act H.R. 4368/S. 2131, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2024 H.R. 4394/S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024 H.R. 4821/S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024 H.R. 5089, Reducing Regulatory Burdens Act of 2024 H.R. 7008, Judicial Review Timeline Clarity Act H.R. 7013, Confidence in Clean Water Permits Act H.R. 7021, Water Quality Criteria Development and Transparency Act H.R. 7023, Creating Confidence in Clean Water Permitting Act H.R. 7206, Reducing Permitting Uncertainty Act H.R. 7284, No IRIS Act of 2024 H.R. 7650, Air Quality Standards Implementation Act of 2024 H.R. 8030/S. 4134, Drought Relief Obtained Using Government Help Today Act of 2024 H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 H.R. 8204, Regulatory Early Notice and Engagement Act of 2024 H.R. 8467, Farm, Food, and National Security Act of 2024 H.R. 8812, Water Resources Development Act of 2024 H.R. 8998, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025 S. 1189, Recycling Infrastructure and Accessibility Act of 2023 S. 1194, Recycling and Composting Accountability Act of 2023 S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act S. 2283, PFAS-Free Procurement Act of 2023 S. 3067, Facilitating Hazard Mitigations Project Act S. 3261, National Coordination on Adaptation and Resilience for Security Act S. 3439, Concrete and Asphalt Innovation Act of 2023 S. 3719, Sound Science for Farmers Act of 2024 S. 3826, Modernizing Clean Air Permitting Act of 2024 S. 4367, Water Resources Development Act S. 4927, Energy and Water Development and Related Agencies Appropriations Act, 2025 H.Res. 114/S.J.Res. 61, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Federal Highway Administration relating to "National Performance Management Measures; Assessing Performance of the National Highway System, Greenhouse Gas Emissions Measure 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 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" H.J.Res. 127/S.J.Res. 72, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "The Enhancement and Standardization of Climate-Related Disclosures for Investors" H.J.Res.161, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry" 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 Draft legislation titled Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2025 Interior, Environment, and Related Agencies Appropriations Act Draft legislation titled Fiscal Year 2025 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2025 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation to amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to reauthorize brownfields revitalization funding, and for other purposes Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to fugitive methane emissions 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 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. 2820/S. 1251, Growing Climate Solutions Act of 2021 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 4309, Clean Energy Innovation and Deployment Act of 2021 Potential legislation similar to H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to e-waste export controls and Buy America 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, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 7792, Water Data Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to S. 2377, Energy Infrastructure Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislation similar to S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislative action similar to H.J.Res.91/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 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 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) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, (86 Fed. Reg. 43,726-43,811, August 10, 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) Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (87 Fed. Reg. 14,104-14,142, March 11, 2022) Certification of New Interstate Natural Gas Facilities (87 Fed. Reg. 11,548-11,580, March 1, 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) 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) Notice of Public Meeting: Environmental Justice Considerations for the Development of the Proposed Per- and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation (NPDWR) (87 Fed. Reg. 7,412-7,413, February 9, 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) Request for Public Comment, Draft National Strategy to Prevent Plastic Pollution: Request for Public Comment (88 Fed. Reg. 27,502-27,504, May 2, 2023) Advance Notice of Proposed Rulemaking, Addressing PFAS in the Environment (88 Fed. Reg. 22,399-22,403, April 13, 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) Proposed Rule, Environmental Protection Agency; Per- and Poly-Fluoroalkyl Chemical Substances Designated as Inactive on the TSCA Inventory; Significant New Use Rule (88 Fed. Reg. 4,937-4,945 January 26, 2023) Public Comment, Environmental Protection Agency; National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (88 Fed. Reg. 2,093-2,097, January 12, 2023) Notice of Availability and Request for Information; Consumer Product Safety Commission; Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (88 Fed. Reg. 64,890-64,892, September 20, 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. 65,350-65356, 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) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; 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 provisions 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); implementation of Section 45V of the Inflation Reduction Act (P.L. 117-169): Credit for Production of Clean Hydrogen; funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.- Mexico water policy; issues related to the definition and implementation of Waters of the United States; 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); energy production in the Arctic; 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; toxicity classification of plastics in Canada; Department of the Interiors comprehensive review of the federal oil and gas program as called for in Executive Order 14008; deployment of Smart Water Infrastructure Technology; the Border Water Infrastructure Program; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; regulation of and issues related to perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; provisions in the Fiscal Year 2024 National Defense Authorization Act (NDAA), related to perfluoroalkyls and polyfluoroalkyl chemicals (PFAS); request to extend the public comment period for EPAs upcoming review of MCL research; 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; ratification of the Kigali Amendment to the Montreal Protocol; climate-related financial risk management for large banks; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; national emissions standards for hazardous air pollutants for existing combustion turbines; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Ecosystem Services Guidance and Natural Capital Accounting for cost benefit analyses; social cost of greenhouse gases policy; environmental justice; Conference of the Parties (COP) 28; infrastructure and permitting including the White House Permitting Action Plan; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; small and disadvantaged community water issues; 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; carbon border adjustments; 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; Department of Energy Greenhouse Gas Supply Chain Measurement, Monitoring, Reporting, and Verification (MMRV) Framework; 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; EU PFAS regulations; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; Health Canada PFAS in drinking water consultation; Canadas State of PFAS Report; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; UN water conference; 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; priorities for the upcoming Fiscal Year 2024 Farm Bill; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; and 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); Basel Convention Act of 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); existing and new chemical regulations

EPA Rulemaking Restricting Ethylene Oxide (ETO) - Proposed rulemaking to place more-stringent limits on emissions and institute new monitoring requirements for ethylene oxide (ETO). Advocacy efforts include educating lawmakers on the importance of ETO in the sterilization of medical devices and potential shortages of sterile medical devices if EPA's proposed changes are enacted. PFAS-Free Procurement Act of 2023 (S.2283) and Draft Legislation from Sens. Carper and Capito to improve the mitigation and remediation of PFAS contamination.

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. S. 4187 and H.R. 8074, Forever Chemical Regulation & Accountability Act of 2024, including provisions related to a non-essential use ban of PFAS chemicals and CERCLA liability waivers. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. Potential legislation to promote the competitiveness of domestic polymer manufacturing and use. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxics Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

P.L. 117-58, Inflation Reduction Act; P.L. 117-169, Bipartisan Infrastructure Law; H.J. Res. 117, 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"; H.J. Res 123, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention"; H.J. Res. 161, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry"; H.R. 1, Lower Energy Cost Act including provisions on chemical reviews; H.R. 815, Making emergency supplemental appropriations for the fiscal year ending September 30, 2024, and for other purposes; H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes. Climate policy/carbon emissions reduction; H.R. 1158, Elimination of Future Technology Delays Act of 2023; H.R. 1517, Relief for Farmers Hit with PFAS Act; H.R. 1633, Reducing Accidents In Locomotives (RAIL) Act; H.R. 1674, 1674 Railway Safety Act of 2023; H.R. 2670, National Defense Authorization Act for FY 2024 (including chemical management provisions Subtitle C, Sections 331-336; H.R. 2811, Limit, Save, Grow Act of 2023; H.R. 3716, SPUR Act; H.R. 3746, Fiscal Responsibility Act; H.R. 3935, Securing Growth and Robust Leadership in American Aviation Act; H.R. 3938, Build It In America Act; H.R. 3953, Debt Ceiling Reform Act; H.R. 4040, Recycling and Composting Accountability Act; H.R. 4194, Protecting Communities from Plastics Act of 2024; H.R. 4310, Youth Poisoning Protection Act; H.R. 4366, Consolidated Appropriations Act, 2024; H.R. 4470, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; H.R. 4561, Reducing Waste in National Parks Act; H.R. 4821, Department of the Interior, Environment, and Related Agencies Appropriations Act 2024; including 518; H.R. 4893, Scientific Integrity Act; H.R. 5260, PFAS Free Military Purchasing Act; H.R. 5860, Continuing Appropriations Act, 2024 and Other Extensions Act; H.R. 6053, Break Free from Plastic Pollution Act of 2023; H.R. 6159, Recycling Infrastructure and Accessibility Act; H.R. 6363, Further Continuing Appropriation and Other Extensions Act, 2024; H.R. 6454 Chemical Tax Repeal Act; H.R. 6532, Renewable Chemicals Act; H.R. 6654, Farewell to Foam Act of 2023; H.R. 6805, PFAS Action Act of 2023; H.R. 7194, PFAS Accountability Act; H.R 7284, No IRIS Act; H.R. 7775, PFAS-Free Procurement Act of 2024; H.R. 7980, End Chinese Dominance of Electric Vehicles in America Act of 2024; H.R. 8034, Israel Security Supplemental Appropriations Act, 2024; H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025; H.R. 8092, Protecting Communities from Plastics Act of 2024; H.R. 8204, Regulatory Early Notice and Engagement Act (RENEA) of 2024; H.R. 8467, Farm, Food, and National Security Act of 2024; H.R. 8774, Department of Defense Appropriations Act, 2024; H.R. 8997, Energy and Water Development and Related Agencies appropriations Act, 2025; H.R. 8998, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025; H. Rept. 118-581, DEPARTMENT OF THE INTERIOR, ENVIRONMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2025; H.R. 9026, Commerce, Justice, Science, and Related Agencies Appropriations Act, 2025; S.J. Res. 100, 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 "New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry."; S. 576, Railway Safety Act of 2023; S. 747, Relief for Farmers Hit with PFAS Act; S. 844, Assistance for Local Heroes During Train Crises Act; S. 866, American Innovation and Jobs Act; S. 1189, Recycling Infrastructure and Accessibility Act; S. 1194, Recycling and Composting Accountability Act; S. 1195, Chemical Tax Repeal Act; S. 1427, Agriculture PFAS Liability Protection Act of 2023; S. 1429, Resource Management PFAS Liability Protection Act of 2023; S. 1430, Water Systems PFAS Liability Protection Act of 2023; S. 1432, Fire Suppression PFAS Liability Protection Act of 2023; S. 1433, Airports PFAS Liability Protection Act of 2023; S. 1449, RESTART Act; S. 1456, SPUR Act; S. 1863, PROVE IT Act; S. 1882, Debt Ceiling Reform Act; S. 1939, FAA Reauthorization Act of 2023; S. 2178, A bill to extend the Chemical Facility Anti-Terrorism Standards Program of the Department of Homeland Security, and for other purposes; S. 2226, National Defense Authorization Act for FY 2024, including Title III, Section 321; S. 2233, Youth Poisoning Protection Act; S. 2283, PFAS-Free Procurement Act of 2023; S. 2337, Plastic Pellet Free Waters Act; S. 2499, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; S. 2728, Reducing Waste in National Parks Act; S. 2844, REDUCE Act of 2023; S. 3127, Break Free from Plastic Pollution Act of 2023; S. 3512, The Truth in Labeling Act of 2024; S. 3719, Sound Science for Farmers Act; S. 3724, No IRIS Act; S. 3725, PFAS Accountability Act; S. 4194, Protecting Communities form Plastics Act of 2024; S. 4638, National Defense Authorization Act for Fiscal Year 2025; FY2024 Department of Interior, Environment, and Related Agencies Appropriations; FY2024 National Defense Authorization Act, use of advanced materials in infrastructure; FY2025 National Defense Authorization, including use of advanced materials in infrastructure; FY2025 Agriculture Rural Development, FDA, and Related Agencies; FY2025 Commerce, Justice, Science, and Related Agencies; FY2025 Department of Energy Appropriations; FY2025 THUD and Energy and Water Appropriations; Unintroduced FY2024 DOE Appropriations; Unintroduced Legislation - 5 Actions for Sustainable Change; Unintroduced Legislation on Agriculture Policies (Farm Bill) on Chemicals Management Issues; Unintroduced Save Our Seas 3.0; Unintroduced legislation regarding actions for sustainable change; Unintroduced PFAS legislation; Unintroduced Plastic Waste Reduction and Recycling Research Act; Unintroduced Protecting Communities From Plastics Act; Unintroduced legislation dealing with plastic pellet management and microplastics; Unintroduced Regulatory Early Notice and Engagement Act; Unintroduced Senate Energy and Water Development Appropriations Act; 86 Fed. Reg. 50296, Advance Notice of Proposed Rulemaking for Pyrolysis and Gasification; 87 Fed. Reg. 53556, Accidental Release Prevention Requirements: Risk Management Program Under the Clean Air Act; Safer Communities by Chemical Accident Prevention; 88 Fed. Reg. 27502, Draft National Strategy to Prevent Plastic Pollution; 88 Fed. Reg. 39804, SNUR on Certain Chemical Substances (23-2.5e); Automotive Plastics; Basel Convention and Plastic Waste; Biobased Products Procurement and Labeling; Chemical Facilities Anti-Terrorism Standards; Chemicals Management; Climate policy/carbon emissions reduction; Oversight of Department of Energy and Environmental Protection Agency on Chemicals Regulation; Ethylene Oxide; Extended Producer Responsibility; Formaldehyde; Food Contact Regulation for recycled materials; Fourth Session of the Intergovernmental Negotiating Committee to develop a legally binding instrument for plastic pollution; FTC Green Guides 87 Fed. Reg. 77766; Implementation of the Superfund Tax on Chemicals; IRIS appropriations; Microplastics; National Plastics Strategy; Permitting reform; PFAS; PRIA Implementation; Recycling; Proposed SNUR for Fuels Made Using Plastic Waste Based Feedstocks; TSCA Implementation including new chemicals, 1,3-butadiene, formaldehyde, methylene chloride; United Nations Plastics Agreement and Cumulative Impact Assessments Negotiations

H.R. 886, Save our Seas Amendments Act 2.0 H.R. 1152, Water Quality Certification and Energy Project Improvement Act of 2023 H.R. 1435, Preserving Choice in Vehicle Purchases Act H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 H.R. 2670, FY 2024 National Defense Authorization Act H.R. 2925/S. 1281, Mining Regulatory Clarity Act H.R. 2989, Save Our Sequoias Act of 2023 H.R. 3195, Superior National Forest Restoration Act H.R. 3397, Western Economic Security Today Act of 2024 H.R. 4288, Agricultural Labeling Uniformity Act H.R. 4368/S. 2131, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2024 H.R. 4394/S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024 H.R. 4821/S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024 H.R. 5089, Reducing Regulatory Burdens Act of 2024 H.R. 7008, Judicial Review Timeline Clarity Act H.R. 7013, Confidence in Clean Water Permits Act H.R. 7021, Water Quality Criteria Development and Transparency Act H.R. 7023, Creating Confidence in Clean Water Permitting Act H.R. 7206, Reducing Permitting Uncertainty Act H.R. 7650, Air Quality Standards Implementation Act of 2024 H.R. 8030/S. 4134, Drought Relief Obtained Using Government Help Today Act of 2024 H.R. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 H.R. 8204, Regulatory Early Notice and Engagement Act of 2024 H.R. 8467, Farm, Food, and National Security Act of 2024 S. 646, Hydrogen for Industry Act of 2023 S. 647, Hydrogen for Ports Act of 2023 S. 648, Hydrogen for Trucks Act of 2023 S. 649, Hydrogen Infrastructure Finance and Innovation Act S. 1189, Recycling Infrastructure and Accessibility Act of 2023 S. 1194, Recycling and Composting Accountability Act of 2023 S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act S. 2283, PFAS-Free Procurement Act of 2023 S. 3067, Facilitating Hazard Mitigations Project Act S. 3261, National Coordination on Adaptation and Resilience for Security Act S. 3439, Concrete and Asphalt Innovation Act of 2023 S. 3719, Sound Science for Farmers Act of 2024 S. 3826, Modernizing Clean Air Permitting Act of 2024 S. 4367, Water Resources Development Act 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'" H.Res. 114 / S.J.Res. 61, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Federal Highway Administration relating to "National Performance Management Measures; Assessing Performance of the National Highway System, Greenhouse Gas Emissions Measure 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" H.J.Res. 127/S.J.Res. 72, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Securities and Exchange Commission relating to "The Enhancement and Standardization of Climate-Related Disclosures for Investors". 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 Draft legislation titled Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2025 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2025 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation to amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to reauthorize brownfields revitalization funding, and for other purposes Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to fugitive methane emissions 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 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. 2820/S. 1251, Growing Climate Solutions Act of 2021 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 4309, Clean Energy Innovation and Deployment Act of 2021 Potential legislation similar to H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to e-waste export controls and Buy America 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, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 7792, Water Data Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to S. 2377, Energy Infrastructure Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislation similar to S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislative action similar to H.J.Res.91/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 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 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) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, (86 Fed. Reg. 43,726 - 43,811, August 10, 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) Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (87 Fed. Reg. 14,104-14,142, March 11, 2022) Certification of New Interstate Natural Gas Facilities (87 Fed. Reg. 11,548-11,580, March 1, 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) 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) Notice of Public Meeting: Environmental Justice Considerations for the Development of the Proposed Per and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation (NPDWR) (87 Fed. Reg. 7,412-7,413, February 9, 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) Request for Public Comment, Draft National Strategy to Prevent Plastic Pollution: Request for Public Comment (88 Fed. Reg. 27,502-27,504, May 2, 2023) Advance Notice of Proposed Rulemaking, Addressing PFAS in the Environment (88 Fed. Reg. 22,399-22,403, April 13, 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) Proposed Rule, Environmental Protection Agency; Per- and Poly-Fluoroalkyl Chemical Substances Designated as Inactive on the TSCA Inventory; Significant New Use Rule (88 Fed. Reg. 4,937-4,945 January 26, 2023) Public Comment, Environmental Protection Agency; National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (88 Fed. Reg. 2,093-2,097, January 12, 2023) Notice of Availability and Request for Information; Consumer Product Safety Commission; Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (88 Fed. Reg. 64,890-64,892, September 20, 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, Feb. 8, 2024) Request for Congressional Review Act for 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) Proposed Rule, Environmental Protection Agency; Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 8,598-8,606, February 8, 2024) Proposed Rule, Environmental Protection Agency; National Emission Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Amendments (89 Fed. Reg. 9,088-9,103, February 9, 2024) Proposed Rule, Environmental Protection Agency; Clarifying the Scope of Applicable Requirements Under State Operating Permit Programs and the Federal Operating Permit Program, Docket No. EPA-HQ-OAR-2023-0401 (89 Fed. Reg 14,015, February 26, 2024) Proposed Rule, Environmental Protection Agency; Listing of Specific PFAS as Hazardous Constituents (89 Fed. Reg. 8,606-8,621, February 8, 2024) Proposed Rule, Review of the Secondary National Ambient Air Quality Standards for Oxides of Nitrogen, Oxides of Sulfur, and Particulate Matter (89 FR 26,620, April 15, 2024) Proposed Rule, Internal Revenue Service (IRS), Treasury; Superfund Chemical Taxes (88 Fed. Reg. 18,446-18,471, March 29, 2023) Notice, U.S. EPA Criteria or Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials; (Docket EPA-HQ-OPPT-2024-0075) (89 Fed. Reg. 15,868, March 5, 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) 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); Resolution of disapproval under the Congressional Review Act of National Environmental Policy Act Implementing Regulations Revisions Phase 2 (89 Fed. Reg. 35,442-35,577, May 1, 2024); Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; 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 provisions 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); implementation of Section 45V of the Inflation Reduction Act (P.L. 117-169): Credit for Production of Clean Hydrogen; funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.- Mexico water policy; issues related to the definition and implementation of Waters of the United States; 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); energy production in the Arctic; 2024 water policy priorities; 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; toxicity classification of plastics in Canada (to USTR); Department of the Interiors comprehensive review of the federal oil and gas program as called for in Executive Order 14008; deployment of Smart Water Infrastructure Technology; the Border Water Infrastructure Program; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; provisions in the Fiscal Year 2024 National Defense Authorization Act (NDAA), related to perfluoroalkyls and polyfluoroalkyl chemicals (PFAS); request to extend the public comment period for EPAs upcoming review of MCL research; 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; ratification of the Kigali Amendment to the Montreal Protocol; climate-related financial risk management for large banks; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; national emissions standards for hazardous air pollutants for existing combustion turbines; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Ecosystem Services Guidance and Natural Capital Accounting for cost benefit analyses; social cost of greenhouse gases policy; environmental justice; Conference of the Parties (COP) 28; infrastructure and permitting including the White House Permitting Action Plan; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; small and disadvantaged community water issues; 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; carbon border adjustments; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; 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; Department of Energy Greenhouse Gas Supply Chain Measurement, Monitoring, Reporting, and Verification (MMRV) Framework; 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; EU PFAS regulations; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; Health Canada PFAS in drinking water consultation; Canadas State of PFAS Report; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; UN water conference; 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; priorities for the upcoming Fiscal Year 2024 Farm Bill; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; and 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; Basel Convention Act of 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; regulation of and issues related to perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers

EPA Rulemaking Restricting Ethylene Oxide (ETO) - Proposed rulemaking to place more-stringent limits on emissions and institute new monitoring requirements for ethylene oxide (ETO). Advocacy efforts include educating lawmakers on the importance of ETO in the sterilization of medical devices and potential shortages of sterile medical devices if EPA's proposed changes are enacted. PFAS-Free Procurement Act of 2023 (S.2283) and Draft Legislation from Sens. Carper and Capito to improve the mitigation and remediation of PFAS contamination.

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. S. 4187 and H.R. 8074, Forever Chemical Regulation & Accountability Act of 2024, including provisions related to a non-essential use ban of PFAS chemicals and CERCLA liability waivers. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. Potential legislation to promote the competitiveness of domestic polymer manufacturing and use. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxics Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

H.R. 886, Save our Seas Amendments Act 2.0 H.R. 1152, Water Quality Certification and Energy Project Improvement Act of 2023 H.R. 1435, Preserving Choice in Vehicle Purchases Act H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 H.R. 2670, FY 2024 National Defense Authorization Act H.R. 2989, Save Our Sequoias Act of 2023 H.R. 3195, Superior National Forest Restoration Act H.R. 4288, Agricultural Labeling Uniformity Act H.R. 4368/S. 2131, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2024 H.R. 4394/S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024 H.R. 4821/S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024 H.R. 5089, Reducing Regulatory Burdens Act of 2024 H.R. 7008, Judicial Review Timeline Clarity Act H.R. 7013, Confidence in Clean Water Permits Act H.R. 7021, Water Quality Criteria Development and Transparency Act H.R. 7023, Creating Confidence in Clean Water Permitting Act H.R. 7206, Reducing Permitting Uncertainty Act H.R. 7650, Air Quality Standards Implementation Act of 2024 S. 646, Hydrogen for Industry Act of 2023 S. 647, Hydrogen for Ports Act of 2023 S. 648, Hydrogen for Trucks Act of 2023 S. 649, Hydrogen Infrastructure Finance and Innovation Act S. 1189, Recycling Infrastructure and Accessibility Act of 2023 S. 1194, Recycling and Composting Accountability Act of 2023 S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act S. 2283, PFAS-Free Procurement Act of 2023 S. 3067, the Facilitating Hazard Mitigations Project Act S. 3261, the National Coordination on Adaptation and Resilience for Security Act S. 3439, Concrete and Asphalt Innovation Act of 2023 S. 3719, Sound Science for Farmers Act of 2024 S. 3826, Modernizing Clean Air Permitting Act of 2024 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'" H.Res. 114 / S.J.Res. 61, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Federal Highway Administration relating to "National Performance Management Measures; Assessing Performance of the National Highway System, Greenhouse Gas Emissions Measure 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" 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 Draft legislation titled the Wildfire Response Improvement Act Draft legislation to amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to reauthorize brownfields revitalization funding, and for other purposes Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to fugitive methane emissions 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 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. 2515, Building United States Infrastructure through Limited Delays and Efficient Reviews 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. 2820/S. 1251, Growing Climate Solutions Act of 2021 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 4309, Clean Energy Innovation and Deployment Act of 2021 Potential legislation similar to H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to e-waste export controls and Buy America 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, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 7792, Water Data Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to H.R. 8183/S. 3742, Recycling Infrastructure and Accessibility Act of 2022 Potential legislation similar to S. 2377, Energy Infrastructure Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislation similar to S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislative action similar to H.J.Res.91/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 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 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) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, (86 Fed. Reg. 43,726 - 43,811, August 10, 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) Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (87 Fed. Reg. 14,104-14,142, March 11, 2022) Certification of New Interstate Natural Gas Facilities (87 Fed. Reg. 11,548-11,580, March 1, 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) Proposed Rule, Fish and Wildlife Service; Endangered and Threatened Wildlife and Plants, Designation of Experimental Populations (87 Fed. Reg. 34,625-34,629, June 7, 2022) Proposed Rule regarding Revised Definition of Waters of the United States (86 Fed. Reg. 69,372-69,450, December 7, 2021) Proposed Rule, U.S. Fish and Wildlife Service, Department of the Interior; Endangered and Threatened Wildlife and Plants, Endangered Species Status for Tricolored Bat (87 Fed. Reg. 56,381-56,393, September 14, 2022) Proposed Rule, National Environmental Policy Act Implementing Regulations Revisions Phase 2, (88 Fed. Reg. 49,924-49,988, July 31, 2023) 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) Notice of Public Meeting: Environmental Justice Considerations for the Development of the Proposed Per and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation (NPDWR) (87 Fed. Reg. 7,412-7,413, February 9, 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, Nov. 14, 2022) Supplemental Proposed 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 (87 Fed. Reg. 74,702-74,847, December 6, 2022) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Request for Public Comment, Draft National Strategy to Prevent Plastic Pollution: Request for Public Comment (88 Fed. Reg. 27,502-27,504, May 2, 2023) Advance Notice of Proposed Rulemaking, Addressing PFAS in the Environment (88 Fed. Reg. 22,399-22,403, April 13, 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) Proposed Rule, Environmental Protection Agency; Per- and Poly-Fluoroalkyl Chemical Substances Designated as Inactive on the TSCA Inventory; Significant New Use Rule (88 Fed. Reg. 4,937-4,945 January 26, 2023) Public Comment, Environmental Protection Agency; National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (88 Fed. Reg. 2,093-2,097, January 12, 2023) Notice of Availability and Request for Information; Consumer Product Safety Commission; Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (88 Fed. Reg. 64,890-64,892, September 20, 2023) Proposed Rule, Environmental Protection Agency; Used Drum Management and Reconditioning Advance Notice of Proposed Rulemaking (88 Fed. Reg. 54,537-54,548, Aug. 11, 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) 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, Environmental Protection Agency; Definition of Hazardous Waste Applicable to Corrective Action for Releases from Solid Waste Management Units (89 Fed. Reg. 8,598-8,606, February 8, 2024) Proposed Rule, Environmental Protection Agency; National Emission Standards for Hazardous Air Pollutants: Lime Manufacturing Plants Amendments (89 Fed. Reg. 9,088-9,103, February 9, 2024) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; 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 provisions 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); implementation of Section 45V of the Inflation Reduction Act (P.L. 117-169): Credit for Production of Clean Hydrogen; funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.- Mexico water policy; definition of Waters of the United States; 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); energy production in the Arctic; 2024 water policy priorities; 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; toxicity classification of plastics in Canada (to USTR); Department of the Interiors comprehensive review of the federal oil and gas program as called for in Executive Order 14008; deployment of Smart Water Infrastructure Technology; the Border Water Infrastructure Program; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; regulation of and issues related to perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; provisions in the Fiscal Year 2024 National Defense Authorization Act (NDAA), related to perfluoroalkyl and polyfluoroalkyl substances (PFAS); request to extend the public comment period for EPAs upcoming review of MCL research; 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; ratification of the Kigali Amendment to the Montreal Protocol; climate-related financial risk management for large banks; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; national emissions standards for hazardous air pollutants for existing combustion turbines; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Ecosystem Services Guidance and Natural Capital Accounting for cost benefit analyses; social cost of greenhouse gases policy; environmental justice; Conference of the Parties (COP) 28; infrastructure and permitting including the White House Permitting Action Plan; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; water and western water issues; small and disadvantaged community water issues; 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; carbon border adjustments; 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 Strategy 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; Department of Energy Greenhouse Gas Supply Chain Measurement, Monitoring, Reporting, and Verification (MMRV) Framework; EU PFAS regulations; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; Health Canada PFAS in drinking water consultation; Canadas State of PFAS Report; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; UN water conference; 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; priorities for the upcoming Fiscal Year 2024 Farm Bill; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; and EPAs; proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs); Clean Water and Drinking Water State Revolving Funds (SRFs)

P.L. 117-58, Inflation Reduction Act; P.L. 117-169, Bipartisan Infrastructure Law; H.J. Res 117, Disapproved of the National Ambient Air Quality Standards for Particulate Matter rule 89 FR 16202 in the federal register; H.J. Res 123, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention"; H.R. 1, Lower Energy Cost Act including provisions on chemical reviews; H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes. Climate policy/carbon emissions reduction; H.R. 1158, Elimination of Future Technology Delays Act of 2023; H.R. 1517, Relief for Farmers Hit with PFAS Act; H.R. 1633, Reducing Accidents In Locomotives (RAIL) Act; H.R. 1674, 1674 Railway Safety Act of 2023; H.R. 2670, National Defense Authorization Act for FY 2024 (including chemical management provisions Subtitle C, Sections 331-336; H.R. 2811, Limit, Save, Grow Act of 2023; H.R. 3716, SPUR Act; H.R. 3746, Fiscal Responsibility Act; H.R. 3935, Securing Growth and Robust Leadership in American Aviation Act; H.R. 3938, Build It In America Act; H.R. 3953, Debt Ceiling Reform Act; H.R. 4040, Recycling and Composting Accountability Act; H.R. 4310, Youth Poisoning Protection Act; H.R. 4366, Consolidated Appropriations Act, 2024; H.R. 4470, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; H.R. 4821, Department of the Interior, Environment, and Related Agencies Appropriations Act 2024; including 518; H.R. 5260, PFAS Free Military Purchasing Act; H.R. 5860, Continuing Appropriations Act, 2024 and Other Extensions Act; H.R. 6053, Break Free from Plastic Pollution Act of 2023; H.R. 6159, Recycling Infrastructure and Accessibility Act; H.R. 6363, Further Continuing Appropriation and Other Extensions Act, 2024; H.R. 6454 Chemical Tax Repeal Act; H.R. 6654, Farewell to Foam Act of 2023; H.R. 6805, PFAS Action Act of 2023; H.R. 7194, PFAS Accountability Act; S. 576, Railway Safety Act of 2023; S. 747, Relief for Farmers Hit with PFAS Act; S. 844, Assistance for Local Heroes During Train Crises Act; S. 866, American Innovation and Jobs Act; S. 1189, Recycling Infrastructure and Accessibility Act; S. 1194, Recycling and Composting Accountability Act; S. 1195, Chemical Tax Repeal Act; S. 1427, Agriculture PFAS Liability Protection Act of 2023; S. 1429, Resource Management PFAS Liability Protection Act of 2023; S. 1430, Water Systems PFAS Liability Protection Act of 2023; S. 1432, Fire Suppression PFAS Liability Protection Act of 2023; S. 1433, Airports PFAS Liability Protection Act of 2023; S. 1449, RESTART Act; S. 1456, SPUR Act; S. 1863, PROVE IT Act; S. 1882, Debt Ceiling Reform Act; S. 1939, FAA Reauthorization Act of 2023; S. 2178, A bill to extend the Chemical Facility Anti-Terrorism Standards Program of the Department of Homeland Security, and for other purposes; S. 2226, National Defense Authorization Act for FY 2024, including Title III, Section 321; S. 2233, Youth Poisoning Protection Act; S. 2283, PFAS-Free Procurement Act of 2023; S. 2499, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; S. 2844, REDUCE Act of 2023; S. 3127, Break Free from Plastic Pollution Act of 2023; S. 3719, Sound Science for Farmers Act; S. 3725, PFAS Accountability Act; FY2024 Department of Interior, Environment, and Related Agencies Appropriations; FY2024 National Defense Authorization Act, use of advanced materials in infrastructure; FY2025 Department of Interior, Environment, and Related Agencies Appropriations; FY2025 National Defense Authorization, including use of advanced materials in infrastructure; FY2025 National Defense Authorization, including use of advanced materials in infrastructure; FY2025 Agriculture Rural Development, FDA, and Related Agencies; FY2025 Commerce, Justice, Science, and Related Agencies; FY2025 Department of Energy Appropriations; FY2025 THUD and Energy and Water Appropriations; Unintroduced FY2024 DOE Appropriations; Unintroduced Legislation - 5 Actions for Sustainable Change; Unintroduced Legislation on Agriculture Policies (Farm Bill) on Chemicals Management Issues; Unintroduced Save Our Seas 3.0; Unintroduced legislation regarding actions for sustainable change; Unintroduced PFAS legislation; Unintroduced Protecting Communities From Plastics Act; Unintroduced legislation dealing with plastic pellet management and microplastics; Unintroduced Regulatory Early Notice and Engagement Act; 86 Fed. Reg. 50296, Advance Notice of Proposed Rulemaking for Pyrolysis and Gasification; 87 Fed. Reg. 53556, Accidental Release Prevention Requirements: Risk Management Program Under the Clean Air Act; Safer Communities by Chemical Accident Prevention; 88 Fed. Reg. 27502, Draft National Strategy to Prevent Plastic Pollution; 88 Fed. Reg. 39804, SNUR on Certain Chemical Substances (23-2.5e); Automotive Plastics; Basel Convention and Plastic Waste; Biobased Products Procurement and Labeling; Chemical Facilities Anti-Terrorism Standards; Chemicals Management; Climate policy/carbon emissions reduction; Oversight of Department of Energy and Environmental Protection Agency on Chemicals Regulation; Ethylene Oxide; Formaldehyde; Food Contact Regulation for recycled materials; FTC Green Guides 87 Fed. Reg. 77766; Implementation of the Superfund Tax on Chemicals; IRIS appropriations; Microplastics; National Plastics Strategy; Permitting reform; PFAS; PRIA Implementation; Recycling; Proposed SNUR for Fuels Made Using Plastic Waste Based Feedstocks; Third Session of the Intergovernmental Negotiating Committee to develop a legally binding instrument for plastic pollution; TSCA Implementation including new chemicals, 1,3-butadiene, formaldehyde, methylene chloride; United Nations Plastics Agreement and Cumulative Impact Assessments Negotiations

EPA Rulemaking Restricting Ethylene Oxide (ETO) - Proposed rulemaking to place more-stringent limits on emissions and institute new monitoring requirements for ethylene oxide (ETO). Advocacy efforts include educating lawmakers on the importance of ETO in the sterilization of medical devices and potential shortages of sterile medical devices if EPA's proposed changes are enacted. PFAS-Free Procurement Act of 2023 (S.2283) and Draft Legislation from Sens. Carper and Capito to improve the mitigation and remediation of PFAS contamination.

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. Potential legislation to promote the competitiveness of domestic polymer manufacturing and use. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxics Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-0496, 88 Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

CERCLA PFAS regulation; recyclable organics; S.820, Protecting Consumers from PFAS Act; S.2283 PFAS-Free Procurement Act of 2023;

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

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

H.R. 1152, Water Quality Certification and Energy Project Improvement Act of 2023 H.R. 1435, Preserving Choice in Vehicle Purchases Act H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 H.R. 2670, FY 2024 National Defense Authorization Act H.R. 2989, Save Our Sequoias Act of 2023 H.R. 3195, Superior National Forest Restoration Act H.R. 4288, Agricultural Labeling Uniformity Act H.R. 4368/S. 2131, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2024 H.R. 4394/S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024 H.R. 4821/S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024 S. 646, Hydrogen for Industry Act of 2023 S. 647, Hydrogen for Ports Act of 2023 S. 648, Hydrogen for Trucks Act of 2023 S. 649, Hydrogen Infrastructure Finance and Innovation Act S. 1189, Recycling Infrastructure and Accessibility Act of 2023 S. 1194, Recycling and Composting Accountability Act of 2023 S. 1863, A bill to require the Secretary of Energy to conduct a study and submit a report on the greenhouse gas emissions intensity of certain products S. 2283, PFAS-Free Procurement Act of 2023 S. 3067, the Facilitating Hazard Mitigations Project Act S. 3261, the National Coordination on Adaptation and Resilience for Security Act 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'" 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 S.J.Res. 9, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the United States Fish and Wildlife Service relating to Endangered and Threatened Wildlife and Plants; Lesser Prairie-Chicken; Threatened Status With Section 4(d) Rule for the Northern Distinct Population Segment and Endangered Status for the Southern Distinct Population Segment S.J.Res. 24, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the United States Fish and Wildlife Service relating to "Endangered and Threatened Wildlife and Plants; Endangered Species Status for Northern Long-Eared Bat" Draft legislation titled Fiscal Year 2024 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2024 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2024 Department of Agriculture Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation to amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to reauthorize brownfields revitalization funding, and for other purposes Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to fugitive methane emissions 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 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. 2515, Building United States Infrastructure through Limited Delays and Efficient Reviews 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. 2820/S. 1251, Growing Climate Solutions Act of 2021 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 4309, Clean Energy Innovation and Deployment Act of 2021 Potential legislation similar to H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to e-waste export controls and Buy America 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, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 7792, Water Data Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to H.R. 8168, Save our Sequoias Act Potential legislation similar to H.R. 8183/S. 3742, Recycling Infrastructure and Accessibility Act of 2022 Potential legislation similar to S. 2377, Energy Infrastructure Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislation similar to S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislative action similar to H.J.Res.91/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 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 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) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, (86 Fed. Reg. 43,726 - 43,811, August 10, 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) Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (87 Fed. Reg. 14,104-14,142, March 11, 2022) Certification of New Interstate Natural Gas Facilities (87 Fed. Reg. 11,548-11,580, March 1, 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) Proposed Rule, Fish and Wildlife Service; Endangered and Threatened Wildlife and Plants, Designation of Experimental Populations (87 Fed. Reg. 34,625-34,629, June 7, 2022) Proposed Rule regarding Revised Definition of Waters of the United States (86 Fed. Reg. 69,372-69,450, December 7, 2021) Proposed Rule, U.S. Fish and Wildlife Service, Department of the Interior; Endangered and Threatened Wildlife and Plants, Endangered Species Status for Tricolored Bat (87 Fed. Reg. 56,381-56,393, September 14, 2022) 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) Notice of Public Meeting: Environmental Justice Considerations for the Development of the Proposed Per- and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation (NPDWR) (87 Fed. Reg. 7,412-7,413, February 9, 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) Supplemental Proposed 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 (87 Fed. Reg. 74,702-74,847, December 6, 2022) Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (88 Fed. Reg. 5,558-5,719, January 27, 2023) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Request for Public Comment, Draft National Strategy to Prevent Plastic Pollution: Request for Public Comment (88 Fed. Reg. 27,502-27,504, May 2, 2023) Advance Notice of Proposed Rulemaking, Addressing PFAS in the Environment (88 Fed. Reg. 22,399-22,403, April 13, 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) Proposed Rule, Environmental Protection Agency; Per- and Poly-Fluoroalkyl Chemical Substances Designated as Inactive on the TSCA Inventory; Significant New Use Rule (88 Fed. Reg. 4,937-4,945 January 26, 2023) Public Comment, Environmental Protection Agency; National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (88 Fed. Reg. 2,093-2,097, January 12, 2023) Implementation of the Final Rule, Environmental Protection Agency; Phasedown of Hydrofluorocarbons: Restrictions on the Use of Certain Hydrofluorocarbons Under the American Innovation and Manufacturing Act of 2020 (88 Fed. Reg. 73,098-73,212, October 24, 2023) Notice of Availability and Request for Information; Consumer Product Safety Commission; Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (88 Fed. Reg. 64,890-64,892, September 20, 2023) Proposed Rule, Bureau of Land Management, Department of the Interior; Management and Protection of the National Petroleum Reserve in Alaska (88 Fed. Reg. 62,025-62,043, September 8, 2023) Proposed Rule, Environmental Protection Agency; Review of Final Rule Reclassification of Major Sources as Area Sources Under Section 112 of the Clean Air Act (88 Fed. Reg. 66,336-66,351, Sept. 27, 2023) Proposed Rule, Environmental Protection Agency; Revisions to the Air Emissions Reporting Requirements (88 Fed. Reg. 54,118-54,222, August 9, 2023) Proposed Rule, Environmental Protection Agency; Used Drum Management and Reconditioning Advance Notice of Proposed Rulemaking (88 Fed. Reg. 54,537-54,548, Aug. 11, 2023) Proposed Rule, National Highway Traffic Safety Administration; Corporate Average Fuel Economy Standards for Passenger Cars and Light Trucks for Model Years 2027-2032 and Fuel Efficiency Standards for Heavy-Duty Pickup Trucks and Vans for Model Years 2030-2035 (88 Fed. Reg. 56,128-56,390, August 17, 2023) Proposed Rule, Office of National Marine Sanctuaries (ONMS), National Ocean Service, National Oceanic and Atmospheric Administration (NOAA), Department of Commerce; Proposed Chumash Heritage National Marine Sanctuary (88 Fed. Reg. 58,123-58,145, August 25, 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) 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) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; 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 provisions 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); implementation of Section 45V of the Inflation Reduction Act (P.L. 117-169): Credit for Production of Clean Hydrogen; funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.- Mexico water policy; definition of Waters of the United States; 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); energy production in the Arctic; 2024 water policy priorities; 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; toxicity classification of plastics in Canada (to USTR); Department of the Interiors comprehensive review of the federal oil and gas program as called for in Executive Order 14008; deployment of Smart Water Infrastructure Technology; the Border Water Infrastructure Program; 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; Provisions in the Fiscal Year 2024 National Defense Authorization Act (NDAA), related to perfluoroalkyl and polyfluoroalkyl substances (PFAS); request to extend the public comment period for EPAs upcoming review of MCL research; 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; ratification of the Kigali Amendment to the Montreal Protocol; climate-related financial risk management for large banks; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; Section 333 of the National Defense Authorization Act for Fiscal Year 2024 conference agreement, relating to procurement of certain products containing per- and polyfluoroalkyl substances (PFAS); national emissions standards for hazardous air pollutants for existing combustion turbines; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; social cost of greenhouse gases policy; environmental justice; Conference of the Parties (COP) 28; infrastructure and permitting including the White House Permitting Action Plan; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; Per- and polyfluoroalkyl substances (PFAS) issues; water and western water issues; small and disadvantaged community water issues; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; regional roundtable discussions regarding Waters of the United States; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; carbon border adjustments; 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 Strategy 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; Department of Energy Greenhouse Gas Supply Chain Measurement, Monitoring, Reporting, and Verification (MMRV) Framework; EU PFAS regulations; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; Health Canada PFAS in drinking water consultation; Canadas State of PFAS Report; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; UN water conference; 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; priorities for the upcoming Fiscal Year 2024 Farm Bill; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; and EPAs; proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs)

P.L. 117-58, Inflation Reduction Act; P.L. 117-169, Bipartisan Infrastructure Law; H.R. 1, Lower Energy Cost Act including provisions on chemical reviews; H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes. Climate policy/carbon emissions reduction; H.R. 1158, Elimination of Future Technology Delays Act of 2023; H.R. 1633, Reducing Accidents In Locomotives (RAIL) Act; H.R. 1674, 1674 Railway Safety Act of 2023; H.R. 2670, National Defense Authorization Act for FY 2024 (including chemical management provisions Subtitle C, Sections 331-336; H.R. 2811, Limit, Save, Grow Act of 2023; H.R. 3716, SPUR Act; H.R. 3746, Fiscal Responsibility Act; H.R. 3935, Securing Growth and Robust Leadership in American Aviation Act; H.R. 3938, Build It In America Act; H.R. 3953, Debt Ceiling Reform Act; H.R. 4310, Youth Poisoning Protection Act; H.R. 4470, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; H.R. 4821, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; H.R. 5260, PFAS Free Military Purchasing Act; H.R. 5860, Continuing Appropriations Act, 2024 and Other Extensions Act; H.R. 6053, Break Free from Plastic Pollution Act of 2023; H.R. 6363, Further Continuing Appropriation and Other Extensions Act, 2024; H.R. 6654, Farewell to Foam Act of 2023; H.R. 6805, PFAS Action Act of 2023; S. 576, Railway Safety Act of 2023; S. 844, Assistance for Local Heroes During Train Crises Act; S. 866, American Innovation and Jobs Act; S. 1189, Recycling Infrastructure and Accessibility Act; S. 1194, Recycling and Composting; S. 1195, Chemical Tax Repeal Act; S. 1427, Agriculture PFAS Liability Protection Act of 2023; S. 1429, Resource Management PFAS Liability Protection Act of 2023; S. 1430, Water Systems PFAS Liability Protection Act of 2023; S. 1432, Fire Suppression PFAS Liability Protection Act of 2023; S. 1433, Airports PFAS Liability Protection Act of 2023; S. 1449, RESTART Act; S. 1456, SPUR Act; S. 1863, PROVE IT Act; S. 1882, Debt Ceiling Reform Act; S. 1939, FAA Reauthorization Act of 2023; S. 2178, A bill to extend the Chemical Facility Anti-Terrorism Standards Program of the Department of Homeland Security, and for other purposes; S. 2226, National Defense Authorization Act for FY 2024, including Title III, Section 321; S. 2233, Youth Poisoning Protection Act; S. 2283, PFAS-Free Procurement Act of 2023; S. 2499, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; S. 2844, REDUCE Act of 2023; S. 3127, Break Free from Plastic Pollution Act of 2023; FY2024 Department of Interior, Environment, and Related Agencies Appropriations; FY2024 National Defense Authorization Act, use of advanced materials in infrastructure; Unintroduced FY2024 DOE Appropriations; Unintroduced Legislation - 5 Actions for Sustainable Change; Unintroduced Legislation on Agriculture Policies (Farm Bill) on Chemicals Management Issues; Unintroduced Save Our Seas 3.0; Unintroduced legislation regarding actions for sustainable change; Unintroduced PFAS legislation; Unintroduced Protecting Communities From Plastics Act; Unintroduced legislation dealing with plastic pellet management and microplastics; 86 Fed. Reg. 50296, Advance Notice of Proposed Rulemaking for Pyrolysis and Gasification; 87 Fed. Reg. 53556, Accidental Release Prevention Requirements: Risk Management Program Under the Clean Air Act; Safer Communities by Chemical Accident Prevention; 88 Fed. Reg. 27502, Draft National Strategy to Prevent Plastic Pollution; 88 Fed. Reg. 39804, SNUR on Certain Chemical Substances (23-2.5e); Automotive Plastics; Basel Treaty; Chemical Facilities Anti-Terrorism Standards; Chemicals Management; Climate policy/carbon emissions reduction; Oversight of Department of Energy and Environmental Protection Agency on Chemicals Regulation; Ethylene Oxide; Formaldehyde; Food Contact Regulation for recycled materials; FTC Green Guides 87 Fed. Reg. 77766; Implementation of the Superfund Tax on Chemicals; IRIS appropriations; Microplastics; National Plastics Strategy; Permitting reform; PFAS; PRIA Implementation; Recycling; Proposed SNUR for Fuels Made Using Plastic Waste Based Feedstocks; Third Session of the Intergovernmental Negotiating Committee to develop a legally binding instrument for plastic pollution; TSCA Implementation including new chemicals, 1,3-butadiene, formaldehyde, methylene chloride; United Nations Plastics Agreement and Cumulative Impact Assessments Negotiations

EPA Rulemaking Restricting Ethylene Oxide (ETO) - Proposed rulemaking to place more-stringent limits on emissions and institute new monitoring requirements for ethylene oxide (ETO). Advocacy efforts include educating lawmakers on the importance of ETO in the sterilization of medical devices and potential shortages of sterile medical devices if EPA's proposed changes are enacted. PFAS-Free Procurement Act of 2023 (S.2283) and Draft Legislation from Sens. Carper and Capito to improve the mitigation and remediation of PFAS contamination.

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. Potential House legislation requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation directing EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. EPA's proposed Toxis Substances Control Act risk management rule for Trichloroethylene (TCE), EPA-HQ-OPPT-2020-0642-0026, 88 Fed. Reg. 74,712 (Oct. 31, 2023). EPA's Proposed Rule on Procedures for Chemical Risk Evaluation Under the Toxic Substances Control Act, Docket No. EPA-HQ-OPPT-2023-049688, Fed. Reg. 74,292 (Oct. 30, 2023). White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries. Consumer Product Safety Administration' Notice on Per- and Polyfluoroalkyl Substances (PFAS) in Consumer Products (CPSC-2023-0033). Department of Defense report on the critical uses of per- and polyfluoroalkyl substance uses (August 2023).

P.L. 117-58, Inflation Reduction Act; P.L. 117-169, Bipartisan Infrastructure Law; H.R. 1, Lower Energy Cost Act including provisions on chemical reviews; H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes. Climate policy/carbon emissions reduction; H.R. 1158, Elimination of Future Technology Delays Act of 2023; H.R. 1633, Reducing Accidents In Locomotives (RAIL) Act; H.R. 1674, 1674 Railway Safety Act of 2023; H.R. 2670, National Defense Authorization Act for FY 2024 (including chemical management provisions Subtitle C, Sections 331-333; H.R. 2811, Limit, Save, Grow Act of 2023; H.R. 3716, SPUR Act; H.R. 3746, Fiscal Responsibility Act; H.R. 3935, Securing Growth and Robust Leadership in American Aviation Act; H.R. 3938, Build It In America Act; H.R. 3953, Debt Ceiling Reform Act; H.R. 4310, Youth Poisoning Protection Act; H.R. 4470, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; H.R. 4821, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; H.R. 5260, PFAS Free Military Purchasing Act; S. 576, Railway Safety Act of 2023; S. 844, Assistance for Local Heroes During Train Crises Act; S. 866, American Innovation and Jobs Act; S. 1189, Recycling Infrastructure and Accessibility Act; S. 1194, Recycling and Composting; S. 1195, Chemical Tax Repeal Act; S. 1427, Agriculture PFAS Liability Protection Act of 2023; S. 1429, Resource Management PFAS Liability Protection Act of 2023; S. 1430, Water Systems PFAS Liability Protection Act of 2023; S. 1432, Fire Suppression PFAS Liability Protection Act of 2023; S. 1433, Airports PFAS Liability Protection Act of 2023; S. 1449, RESTART Act; S. 1456, SPUR Act; S. 1863, PROVE IT Act; S. 1882, Debt Ceiling Reform Act; S. 1939, FAA Reauthorization Act of 2023; S. 2178, A bill to extend the Chemical Facility Anti-Terrorism Standards Program of the Department of Homeland Security, and for other purposes; S. 2226, National Defense Authorization Act for FY 2024; S. 2233, Youth Poisoning Protection Act; S. 2283, PFAS-Free Procurement Act of 2023; S. 2499, Protecting and Securing Chemical Facilities from Terrorist Attacks Act of 2023; S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024; S. 2844, REDUCE Act of 2023; FY2024 Department of Interior, Environment, and Related Agencies Appropriations; FY2024 National Defense Authorization Act, use of advanced materials in infrastructure; Unintroduced FY2024 DOE Appropriations; Unintroduced Legislation - 5 Actions for Sustainable Change; Unintroduced Legislation on Agriculture Policies (Farm Bill) on Chemicals Management Issues; Unintroduced Save Our Seas 3.0; Unintroduced Break Free From Plastic Pollution Act; Unintroduced legislation regarding actions for sustainable change; Unintroduced PFAS legislation; Unintroduced Protecting Communities From Plastics Act; 86 Fed. Reg. 50296, Advance Notice of Proposed Rulemaking for Pyrolysis and Gasification; 88 Fed. Reg. 27502, Draft National Strategy to Prevent Plastic Pollution; 88 Fed. Reg. 39804, SNUR on Certain Chemical Substances (23-2.5e); Automotive Plastics; Basel Treaty; Chemical Facilities Anti-Terrorism Standards; Chemicals Management; Climate policy/carbon emissions reduction; Oversight of Department of Energy and Environmental Protection Agency on Chemicals Regulation; Ethylene Oxide; Formaldehyde; Food Contact Regulation for recycled materials; FTC Green Guides 87 Fed. Reg. 77766; Implementation of the Superfund Tax on Chemicals; IRIS appropriations; Microplastics; National Plastics Strategy; Permitting reform; PFAS; PRIA Implementation; Recycling; TSCA Implementation including new chemicals, 1,3-butadiene, formaldehyde, methylene chloride; United Nations Plastics Agreement and Cumulative Impact Assessments Negotiations

H.R. 1152, Water Quality Certification and Energy Project Improvement Act of 2023 H.R. 1435, Preserving Choice in Vehicle Purchases Act H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 H.R. 2670, FY 2024 National Defense Authorization Act H.R. 2989, Save Our Sequoias Act of 2023 H.R. 3195, Superior National Forest Restoration Act H.R. 4288, Agricultural Labeling Uniformity Act H.R. 4368/S. 2131, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2024 H.R. 4394/S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024 H.R. 4821/S. 2605, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2024 S. 646, Hydrogen for Industry Act of 2023 S. 647, Hydrogen for Ports Act of 2023 S. 648, Hydrogen for Trucks Act of 2023 S. 649, Hydrogen Infrastructure Finance and Innovation Act S. 1189, Recycling Infrastructure and Accessibility Act of 2023 S. 1194, Recycling and Composting Accountability Act of 2023 S. 1863, A bill to require the Secretary of Energy to conduct a study and submit a report on the greenhouse gas emissions intensity of certain products S. 2283, PFAS-Free Procurement Act of 2023 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'" 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 S.J.Res. 9, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the United States Fish and Wildlife Service relating to Endangered and Threatened Wildlife and Plants; Lesser Prairie-Chicken; Threatened Status With Section 4(d) Rule for the Northern Distinct Population Segment and Endangered Status for the Southern Distinct Population Segment S.J.Res. 24, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the United States Fish and Wildlife Service relating to "Endangered and Threatened Wildlife and Plants; Endangered Species Status for Northern Long-Eared Bat" Draft legislation titled Fiscal Year 2024 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2024 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2024 Department of Agriculture Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation to amend the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 to reauthorize brownfields revitalization funding, and for other purposes Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to fugitive methane emissions 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 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. 2515, Building United States Infrastructure through Limited Delays and Efficient Reviews 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. 2820/S. 1251, Growing Climate Solutions Act of 2021 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 4309, Clean Energy Innovation and Deployment Act of 2021 Potential legislation similar to H.R. 4521, America Creating Opportunities for Manufacturing, Pre-Eminence in Technology, and Economic Strength (America COMPETES) Act of 2022, including provisions related to e-waste export controls and Buy America 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, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 7792, Water Data Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to H.R. 8168, Save our Sequoias Act Potential legislation similar to H.R. 8183/S. 3742, Recycling Infrastructure and Accessibility Act of 2022 Potential legislation similar to S. 2377, Energy Infrastructure Act Potential legislation similar to S. 2750, Precision Agriculture Loan Program Act of 2021 Potential legislation similar to S. 3531, National Climate Adaptation and Resilience Strategy Act 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 legislation similar to Facilitating Hazard Mitigation Projects Act 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) Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, (86 Fed. Reg. 43,726 - 43,811, August 10, 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) Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews (87 Fed. Reg. 14,104-14,142, March 11, 2022) Certification of New Interstate Natural Gas Facilities (87 Fed. Reg. 11,548-11,580, March 1, 2022) Proposed rule, Asbestos Part 1: Chrysotile Asbestos; Regulation of Certain Conditions of Use Under Advance Notice of Proposed Rulemaking, General Services Administration; Single-Use Plastics and Packaging (87 Fed. Reg. 40,476-40,477, July 7, 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) Proposed Rule, Fish and Wildlife Service; Endangered and Threatened Wildlife and Plants, Designation of Experimental Populations (87 Fed. Reg. 34,625-34,629, June 7, 2022) Proposed Rule regarding Revised Definition of Waters of the United States (86 Fed. Reg. 69,372-69,450, December 7, 2021) Proposed Rule, U.S. Fish and Wildlife Service, Department of the Interior; Endangered and Threatened Wildlife and Plants, Endangered Species Status for Tricolored Bat (87 Fed. Reg. 56,381-56,393, September 14, 2022) 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) Notice of Public Meeting: Environmental Justice Considerations for the Development of the Proposed Per- and Polyfluoroalkyl Substances (PFAS) National Primary Drinking Water Regulation (NPDWR) (87 Fed. Reg. 7,412-7,413, February 9, 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) Supplemental Proposed 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 (87 Fed. Reg. 74,702-74,847, December 6, 2022) Reconsideration of the National Ambient Air Quality Standards for Particulate Matter (88 Fed. Reg. 5,558-5,719, January 27, 2023) Proposed Rule, PFAS National Primary Drinking Water Regulation Rulemaking (88 Fed. Reg. 18,638-18,754, March 29, 2023) Request for Public Comment, Draft National Strategy to Prevent Plastic Pollution: Request for Public Comment (88 Fed. Reg. 27,502-27,504, May 2, 2023) Notice of Meeting and Request for Comment, Environmental Protection Agency; 1,4-Dioxane; Draft Supplement to the TSCA Risk Evaluation; Science Advisory Committee on Chemicals (SACC) Meeting (88 Fed. Reg. 43,562-43,565, July 10, 2023) Notice of Proposed Rulemaking, Council on Environmental Quality National Environmental Policy Act Implementing Regulations Revisions Phase 2 (88 Fed. Reg. 49,924-49,988, July 31, 2023) Proposed Rule, Environmental Protection Agency; Carbon Tetrachloride (CTC), Regulation Under the Toxic Substances Control Act (TSCA) (88 Fed. Reg. 49,180-49,228, July 28, 2023) Proposed Rule, Environmental Protection Agency; Federal Baseline Water Quality Standards for Indian Reservations (88 Fed. Reg. 29,496-29,526, May 5, 2023) Advance Notice of Proposed Rulemaking, Addressing PFAS in the Environment (88 Fed. Reg. 22,399-22,403, April 13, 2023) Notice and Request for Information, Federal Emergency Management Agency, Department of Homeland Security; Community Disaster Resilience Zones and the National Risk Index (88 Fed. Reg. 34,171-34,176, May 26 2023) Proposed Rule, Environmental Protection Agency; State of Louisiana Underground Injection Control Program; Class VI Program Revision Application (88 Fed. Reg. 28,450-28,456, May 4, 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) Proposed Rule, Environmental Protection Agency; National Emission Standards for Hazardous Air Pollutants: Plywood and Composite Wood Products (88 Fed. Reg. 31,856-31,887, May 18, 2023) Proposed Rule, Environmental Protection Agency; National Emission Standards for Hazardous Air Pollutants: Primary Copper Smelting Residual Risk and Technology Review and Primary Copper Smelting Area Source Technology Review (88 Fed. Reg. 47,415-47,437, July 24, 2023) Proposed Rule, Environmental Protection Agency; National Emission Standards for Hazardous Air Pollutants: Taconite Iron Ore Processing Amendments (88 Fed. Reg. 41,872-41,873, June 28, 2023) Request for Comments, Office of Management and Budget; Proposed Guidance for Assessing Changes in Environmental and Ecosystem Services in Benefit-Cost Analysis (88 Fed. Reg. 50,912-50,914, August 2, 2023) Proposed Rule, Environmental Protection Agency; 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. 33,240-33,420, May 23, 2023) Proposed Rule, Environmental Protection Agency; Per- and Poly-Fluoroalkyl Chemical Substances Designated as Inactive on the TSCA Inventory; Significant New Use Rule (88 Fed. Reg. 4,937-4,945 January 26, 2023) Public Comment, Environmental Protection Agency; National Enforcement and Compliance Initiatives for Fiscal Years 2024-2027 (88 Fed. Reg. 2,093-2,097, January 12, 2023) Supplemental Notice of Proposed Rulemaking, Environmental Protection Agency; Fees for the Administration of the Toxic Substances Control Act (TSCA) (87 Fed. Reg. 68,647-68,667, November 16, 2022) Various issues relating to regulatory permit streamlining; nominations for EPA's Social Cost of Greenhouse Gases Peer Review; implementation of Sections 311, 401 and 404 of the Clean Water Act (P.L. 91-190); EPAs Ozone National Ambient Air Quality Standards, including Good Neighbor Air Quality Standards; 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 provisions 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); implementation of Section 45V of the Inflation Reduction Act (P.L. 117-169): Credit for Production of Clean Hydrogen; funding for water infrastructure programs authorized in the Infrastructure Investment and Jobs Act (P.L. 117-58); U.S.- Mexico water policy; definition of Waters of the United States; 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); energy production in the Arctic; 2024 water policy priorities; 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; toxicity classification of plastics in Canada (to USTR); Department of the Interiors comprehensive review of the federal oil and gas program as called for in Executive Order 14008; deployment of Smart Water Infrastructure Technology; the Border Water Infrastructure Program; 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; Provisions in the Fiscal Year 2024 National Defense Authorization Act, related to perfluoroalkyl and polyfluoroalkyl substances (PFAS); request to extend the public comment period for EPAs upcoming review of MCL research; 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; ratification of the Kigali Amendment to the Montreal Protocol; climate-related financial risk management for large banks; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; environmental justice; Conference of the Parties (COP) 28; infrastructure and permitting including the White House Permitting Action Plan; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; Per- and polyfluoroalkyl substances (PFAS) issues; water and western water issues; small and disadvantaged community water issues; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; regional roundtable discussions regarding Waters of the United States; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; carbon border adjustments; 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 Strategy 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; Department of Energy Greenhouse Gas Supply Chain Measurement, Monitoring, Reporting, and Verification (MMRV) Framework; EU PFAS regulations; implementation of Outer Continental Shelf Lands Act (P.L. 83-212); Canadian plastics consultations; Health Canada PFAS in drinking water consultation; Canadas State of PFAS Report; EU REACH PFAS consultation; FTC Green Guides; Global Plastics Pollution Agreement; UN water conference; 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; priorities for the upcoming Fiscal Year 2024 Farm Bill; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; and EPAs; proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs);

EPA Rulemaking Restricting Ethylene Oxide (ETO) - Proposed rulemaking to place more-stringent limits on emissions and institute new monitoring requirements for ethylene oxide (ETO). Advocacy efforts include educating lawmakers on the importance of ETO in the sterilization of medical devices and potential shortages of sterile medical devices if EPA's proposed changes are enacted. PFAS-Free Procurement Act of 2023 (S.2283) and Draft Legislation from Sens. Carper and Capito to improve the mitigation and remediation of PFAS contamination.

Client expense: $380,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 7776, National Defense Authorization Act for Fiscal Year 2023, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS). H.R. 2670, S. 2226, National Defense Authorization Act for Fiscal Year 2024, including provisions related to the regulation of per- and polyfluoroalkyl substances (PFAS) and CERCLA liability waivers. H.R. 2467, PFAS Action Act, including provisions related to requiring EPA to set national drinking water standards and CERCLA designations for certain PFAS compounds. S. 2844, Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act, including provisions related to a virgin plastic resin fee. Potential Senate legislation direction EPA to regulate PFAS in certain sectors and environmental media, and exemptions to CERCLA liability. S. 1903, a bill to require EPA Administrator to revise certain ethylene oxide emission standards under the Clean Air Act. H.R. 3684, Infrastructure Investment and Jobs Act, including provisions related to excise taxes on chemicals, drinking water state revolving funds to address emerging contaminants, and grants focuses on improving material recycling, recovery, management, and reduction. H.R. 1158, Elimination of Future Technology Delays Act of 2023, including provisions related to amending TSCA for chemicals that are a critical energy resource. H.R. 1, Lower Energy Costs Act, including provisions related to streamlining the TSCA process for substances supporting critical energy resources. S.1427, Agriculture PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1433, Airports PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1432, Fire Suppression PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1429, Resource Management PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S.1430, Water Systems PFAS Liability Protection Act, including provisions addressing CERCLA liability exemptions for the releases of PFAS. S. 2283 PFAS-Free Procurement Act of 2023, including provisions related to federal PFAS procurement restrictions of covered products. Potential legislation to support plastics circularity and the emergence of polymer recycling techniques. EPA's PFAS Strategic Roadmap: EPA's Commitments to Action 2021-2024, Oct. 18, 2021. EPA's Advanced Notice of Proposed Rulemaking, Clean Water Act Effluent Limitations Guidelines and Standards for the Organic Chemicals, Plastics and Synthetic Fibers Point Source Category. EPA's Rule on TSCA Section 8(a)(7) Reporting and Recordkeeping Requirements for PFAS Substances. EPA's New Chemical Review process under TSCA, including the low volume and polymer exemptions from TSCA's pre-manufacture notice requirements. EPA's Framework for TSCA New Chemicals Review of PFAS Premanufacture Notices and Significant New Use Notices. EPA's proposed National Primary Drinking Water Regulation (NPDWR) for six PFAS including perfluorooctanoic acid (PFOA), perfluorooctane sulfonic acid (PFOS), perfluorononanoic acid (PFNA), hexafluoropropylene oxide dimer acid (HFPO-DA, commonly known as GenX Chemicals), perfluorohexane sulfonic acid (PFHxS), and perfluorobutane sulfonic acid (PFBS). EPA's Advanced Notice of Proposed Rulemaking on Potential Future Designations of Per- and Polyfluoroalkyl Substances (PFAS) as CERCLA Hazardous Substances, including provisions related to additional designations for seven PFAS chemistries. White House Executive Order on America's Supply Chains, Feb. 24, 2021, including provisions related to high-capacity batteries, critical minerals, and semiconductor manufacturing. Building Resilient Supply Chains, Revitalizing American Manufacturing, and Fostering Broad-Based Growth, 100 day reviews under Executive Order 14017, including provisions related to semiconductors, high-capacity batteries and carbon fiber products for aerospace and defense industries.