CLEAR Act of 2025

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

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

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

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

OCS 5 year leasing program and offshore access issues. Monitor and engage in legislative and administrative action related to general energy policy issues, including offshore development. Monitor and engage in legislative and administrative action related to Gulf of America operations and production increase. Monitor and engage in legislative and administrative action related to permit reform. S. 3305 - CLEAR Act of 2025. H.R.4776 - SPEED Act.

Client expense: $60,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE

S. 3305, the Curtailing Litigation Excess and Abuse Reform Act of 2025, legislation to preclude repeat litigation involving energy projects; entire bill. H.R. 6352, the Curtailing Litigation Excess and Abuse Reform Act of 2025, legislation to preclude repeat litigation involving energy projects; entire bill.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

OCS 5 year leasing program and offshore access issues. Monitor and engage in legislative and administrative action related to general energy policy issues, including offshore development. Monitor and engage in legislative and administrative action related permit reform. S. 3305 - CLEAR Act of 2025.

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

Government targets: SENATE

S. 3305, the CurtailingLitigationExcessandAbuseReformActof 2025, legislation to preclude repeatlitigationinvolving energy projects; entire bill. H.R. 6352, the "Curtailing Litigation ExcessandAbuseReformActof 2025, legislation to preclude repeatlitigationinvolving energy projects; entire bill. S. 2975, the Pipeline Integrity, Protection, and Enhancement for Leveraging Investments in the Nations Energy to assure Safety (PIPELINE Safety) Act, legislation to reauthorize the Pipeline and Hazardous Materials Safety Agency and amend title 49, United States Code, to enhance the safety of pipeline transportation; entire bill. Implementation of the ADVANCE Act of 2024.

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

Government targets: Energy, Dept of, SENATE