Chemical Tax Repeal Act

Superfund fees issues; H.R. 640 / S. 615 H.R. 1 - Budget reconciliation One Big Beautiful Bill Act implementation - business and international tax issues and related issues Budget reconciliation issues

Client expense: $168,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Public Law No: 119-21: One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment, and parity for utilization. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT; H.R. 1, the One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations; Ensuring Better Interest Treatment and Deductibility (EBITDA) Act (S. 4221 & H.R. 8101). Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule.

Client expense: $460,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.640 - Chemical Tax Repeal Act; H.R.6055 - SEMI Investment Act; H.R.8101 - Ensuring Better Interest Treatment and Deductibility Act (EBITDA); H.R.8477 - To amend the Internal Revenue Code of 1986 to reverse certain energy-related modifications enacted by Public Law 119-21 S.615 - Chemical Tax Repeal Act; S.1642 - SEMI Investment Act; S.4221 - Ensuring Better Interest Treatment and Deductibility Act (EBITDA); Draft legislation regarding energy affordability tax incentives; H.R. Reconciliation 3.0; S. Reconciliation 3.0.

Client expense: $2,570,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

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

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

Superfund fees issues; H.R. 640 / S. 615 H.R. 1 - Budget reconciliation One Big Beautiful Bill Act implementation - business and international tax issues and related issues Budget reconciliation issues

Client expense: $260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 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)

Public Law No: 119-21: One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment, and parity for utilization. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT; H.R. 1, the One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations; Ensuring Better Interest Treatment and Deductibility (EBITDA) Act (S. 4221 & H.R. 8101). Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule.

Client expense: $440,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 161, New Source Review Permitting Improvement Act H.R. 278, BROADBAND Leadership Act H.R. 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)

Infrastructure Investment and Jobs Act (Public Law 117-58); Reinstatement of superfund excise tax on chemicals as a funding mechanism; Implementation. Tax Cuts and Jobs Act (Public Law 115-97); Expiring provisions H.R.591 - Defending American Jobs and Investment Act Chemical Tax Repeal Act (S.615)

Client expense: $1,820,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 5376 - Inflation Reduction Act (118th Congress) business and clean energy/EV tax issues and tax credits implementation H.R. 4346 - CHIPS+ Act (118th Congress) implementation Superfund fees issues; H.R. 640 / S. 615 H.R. 1 - Budget reconciliation One Big Beautiful Bill Act implementation - business and international tax issues and related issues

Client expense: $260,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R.640 - Chemical Tax Repeal Act; H.R.8101 - Ensuring Better Interest Treatment and Deductibility Act (EBITDA); H.R.6055 - SEMI Investment Act; S.615 - Chemical Tax Repeal Act; S.1642 - SEMI Investment Act; S.4221 - Ensuring Better Interest Treatment and Deductibility Act (EBITDA).

Client expense: $3,760,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 26: Protecting American Energy Production Act - provisions of the benefits of responsible energy production through the use of hydraulic fracturing. H.J. Res. 57; Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Interior relating to "Oil and Gas and Sulfur Operations in the Outer Continental Shelf-High Pressure High Temperature Updates" - provisions related to the offshore leasing program and efforts to bureaucratically inhibit offshore energy resources through government requirements to the detriment of taxpayers and consumers through higher energy costs. S. 615; Chemical Tax Repeal Act - provisions related to the support of removing arbitrary taxes and penalties on energy producers that result in higher costs for consumers. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the benefits of oil and gas development in the State of Alaska for the permanent fund. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the negative ramifications on commerce for elimination of certain modes of transportation.

Client expense: $305,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 26: Protecting American Energy Production Act - provisions of the benefits of responsible energy production through the use of hydraulic fracturing. H.J. Res. 57; Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Interior relating to "Oil and Gas and Sulfur Operations in the Outer Continental Shelf-High Pressure High Temperature Updates" - provisions related to the offshore leasing program and efforts to bureaucratically inhibit offshore energy resources through government requirements to the detriment of taxpayers and consumers through higher energy costs. S. 615; Chemical Tax Repeal Act - provisions related to the support of removing arbitrary taxes and penalties on energy producers that result in higher costs for consumers. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the benefits of oil and gas development in the State of Alaska for the permanent fund. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the negative ramifications on commerce for elimination of certain modes of transportation.

Client expense: $305,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate H.R.1 One Big Beautiful Bill Act H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate Issues related to Digital Services Taxes Issues related to a remittance tax Issues related to the corporate state and local tax deduction American Innovation and Jobs Act S.1639 Issues related to personal income tax rates

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

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

Public Law No: 119-21: One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment, and parity for utilization. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT; H.R. 1, the One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule.

Client expense: $300,000 · Firm income: Not reported

Government targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE

H.R.640 - Chemical Tax Repeal Act; H.R.6055 - SEMI Investment Act; S.615 - Chemical Tax Repeal Act; S.1642 - SEMI Investment Act.

Client expense: $6,800,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1 - One Big Beautiful Bill Act (Public Law 119-106); 45Q Credit for carbon oxide sequestration, 45V Credit for production of clean hydrogen, 48 Qualifying advanced energy project credit. Infrastructure Investment and Jobs Act (Public Law 117-58); Reinstatement of superfund excise tax on chemicals as a funding mechanism; Implementation. Inflation Reduction Act of 2022 (Public Law 117-169); Incentives for Industrial Decarbonization including Clean Energy Development and Carbon Capture, Utilization, and Storage; Implementation. Tax Cuts and Jobs Act (Public Law 115-97); Expiring provisions H.R.591 - Defending American Jobs and Investment Act Chemical Tax Repeal Act (S.615) Recycling infrastructure tax credit (not yet introduced)

Client expense: $840,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

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

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

H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 2777/S. 1371, S-CAP Act of 2025 H.R. 6055/S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.R. 6231/S. 5370, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 6506, Taxpayer Due Process Enhancement Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Child Care Tax Benefit Outreach and Assistance Act Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024)(as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Certain Disregarded Payments and Dual Consolidated Losses, T.D. 10026, (90 Fed. Reg. 3,003-3,021, January 14, 2025) Various issues relating to conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); implementation and administration of the major business and international tax provisions in the One Big Beautiful Bill Act (Pub. L. No. 119-21); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); potential U.S. legislative and administrative responses to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; advancing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; withdrawal or suspension of the Financial Accounting Standards Boards Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; tax enforcement practices of Mexicos Tax Administration Service; Financial Accounting Standards Board (FASB), Accounting Standards Update 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures

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

Government targets: Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 5376 - Inflation Reduction Act (118th Congress) business and clean energy/EV tax issues and tax credits implementation H.R. 4346 - CHIPS+ Act (118th Congress) implementation Superfund fees issues; H.R. 640 / S. 615 H.R. 1 - Budget reconciliation One Big Beautiful Bill Act - business and international tax issues and related issues House & Senate

Client expense: $310,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate H.R.1 One Big Beautiful Bill Act H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate Issues related to Digital Services Taxes Issues related to a remittance tax Issues related to the corporate state and local tax deduction American Innovation and Jobs Act S.1639 Issues related to personal income tax rates

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

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

Public Law No: 119-21: One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment, and parity for utilization. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT; H.R. 1, the One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule.

Client expense: $310,000 · Firm income: Not reported

Government targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE

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

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

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

H.R. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1177/S. 492, Improve and Enhance the Work Opportunity Tax Credit Act H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act S. 1821, Tackling Predatory Litigation Funding Act H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation responding to the Supreme Court of the United States decision in Commissioner v. Zuch Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) (as corrected by 87 Fed. Reg. 45,018-45,021, July 27, 2022) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); improvements to the Child and Dependent Care Tax Credit (CDCTC), Dependent Care Assistance Program (DCAP), and Employer Provided Child Care Tax Credit (section 45F); U.S. legislative and administrative responses to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; realizing the proposed side-by-side solution described in the G7 Statement on Global Minimum Taxes of June 28, 2025; delay or withdrawal of Financial Accounting Standards Boards (FASB) ASU 2023-09, Income Taxes (Topic 740): Improvements to Income Tax Disclosures; opposing the extraterritorial application of Australias new public country-by-country reporting (PCBCR) regime to U.S. companies; potential inclusion of Tackling Predatory Litigation Funding Act in Senate Finance Committees budget reconciliation (section 70605)

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

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.R. 1 One Big Beautiful Bill Act; H.R. 640 Chemical Tax Repeal Act; H.R. 1415 No IRIS Act of 2025; S. 615 Chemical Tax Repeal Act; S. 1642 SEMI Investment Act; Superfund tax;

Client expense: $3,470,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to corporate tax S.615/H.R.640 - Chemical Tax Repeal Act H.R. 1 - One Bill Beautiful Bill Act (OBBBA) reconciliation package, Section 899 (PL 119-21)

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

H.R. 5376 - Inflation Reduction Act (118th Congress) business and clean energy/EV tax issues and tax credits implementation H.R. 4346 - CHIPS+ Act (118th Congress) implementation Superfund fees issues; H.R. 640 / S. 615 H.R. 1 - Budget reconciliation One Big Beautiful Bill Act - business and international tax issues and related issues House & Senate

Client expense: $231,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

H.R. 1 - One Big Beautiful Bill Act (Public Law 119-106); Section 899, 45Q Credit for carbon oxide sequestration, 45V Credit for production of clean hydrogen, 48 Qualifying advanced energy project credit. Infrastructure Investment and Jobs Act (Public Law 117-58); Reinstatement of superfund excise tax on chemicals as a funding mechanism; Implementation. Inflation Reduction Act of 2022 (Public Law 117-169); Incentives for Industrial Decarbonization including Clean Energy Development and Carbon Capture, Utilization, and Storage; Implementation. Tax Cuts and Jobs Act (Public Law 115-97); Expiring provisions H.R.591 - Defending American Jobs and Investment Act Chemical Tax Repeal Act (S.615) Recycling infrastructure tax credit (not yet introduced)

Client expense: $690,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to corporate tax S.615/H.R.640 - Chemical Tax Repeal Act H.R. 1 - One Bill Beautiful Bill Act (OBBBA) reconciliation package, Section 899 (PL 119-21)

Client expense: Not reported · Firm income: $50,000

Government targets: SENATE

General issues related to corporate tax S.615/H.R.640 - Chemical Tax Repeal Act S.1821/H.R.3512 - Tackling Predatory Litigation Funding Act H.R. 1 - One Bill Beautiful Bill Act (OBBBA) reconciliation package (PL 119-21)

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES

H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate H.R.1 One Big Beautiful Bill Act H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate Issues related to Digital Services Taxes

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

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

H.R. 1 - One Big Beautiful Bill Act (Public Law 119-106); Section 899, 45Q Credit for carbon oxide sequestration, 45V Credit for production of clean hydrogen, 48 Qualifying advanced energy project credit. Infrastructure Investment and Jobs Act (Public Law 117-58); Reinstatement of superfund excise tax on chemicals as a funding mechanism; Implementation. Inflation Reduction Act of 2022 (Public Law 117-169); Incentives for Industrial Decarbonization including Clean Energy Development and Carbon Capture, Utilization, and Storage; Implementation. Tax Cuts and Jobs Act (Public Law 115-97); Expiring provisions H.R.591 - Defending American Jobs and Investment Act Chemical Tax Repeal Act (S.615) Recycling infrastructure tax credit (not yet introduced)

Client expense: $1,540,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment, and parity for utilization. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT; H.R. 1, the One Big Beautiful Bill Act, Sections 70341 and 70342 related to 163(j) limitations. Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule.

Client expense: $320,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), SENATE, Treasury, Dept of

H.R. 1, One Big Beautiful Bill Act H.R. 471, 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. 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. 3928, Improving Water Quality Certifications and American Energy Infrastructure Act H.R. 3927, Nationwide Permitting Improvement Act S. 623, No IRIS 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. 35, Providing for congressional disapproval under chapter 8 of title 5, United States Code, 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" 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" Draft legislation titled Chemical Tax Repeal Act Draft legislation titled Clean Air and Economic Advancement Reform Act (CLEAR Act) Draft legislation titled Clean Air and Building Infrastructure Improvement Act Draft legislation titled Fiscal Year 2026 Energy and Water Development and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Environment and Interior and Related Agencies Appropriations Draft legislation titled Fiscal Year 2026 Commerce, Justice, and Science Agencies Appropriations Draft legislation titled the Wildfire Response Improvement Act Draft legislation titled the FEMA Act Draft legislation on PFAS Draft legislation relating to Basel convention implementing legislation Draft legislation relating to Establishing a Chief Resilience Officer at the White House and calling for interagency coordination and development of a national resilience strategy Draft legislation relating to increasing the portion of post-disaster funding directed for pre-disaster mitigation purposes, especially in FEMAs Building Resilient Infrastructure and Communities Program Draft legislation relating to promoting incentives, including tax credits for individuals and businesses for pre-disaster mitigation expenses Draft legislation to reform the Permitting Councils responsibilities related to assisting federal agencies in the environmental permitting process Potential legislation similar to Recycling Infrastructure and Accessibility Act of 2023 Potential legislation similar to the Recycling and Composting Accountability Act of 2023 Potential legislation similar to National Coordination on Adaptation and Resilience for Security Act Potential legislation similar to H.R. 1435, Preserving Choice in Vehicle Purchases Act Potential legislation similar to H.R. 1812, One Federal Decision Act of 2021 Potential legislation similar to H.R. 2467, PFAS Action Act of 2021 Potential legislation similar to H.R. 2508, Naturally Offsetting Emissions by Managing and Implementing Tillage Strategies Act of 2021 Potential legislation similar to H.R. 2612, Restoring Environments, Soils, Trees, and Operations to develop the Rural Economy (RESTORE) Act of 2021 Potential legislation similar to H.R. 5689, Resilient Assistance for Mitigation for Environmentally Resilient Infrastructure and Construction by Americans (AMERICA) Act Potential legislation similar to H.R. 6461/S. 3531, National Climate Adaptation and Resilience Strategy Act Potential legislation similar to H.R. 8059/S. 3743, Recycling and Composting Accountability Act Potential legislation similar to 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. Nomination of Ms. Jessica Kramer to be the Assistant Administrator of U.S. Environmental Protection Agency Office of Water Nomination of Katherine Scarlett to be Chair of the White House Council on Environmental Quality 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) Extension Request for Draft National Recommended Ambient Water Quality Criteria for the Protection of Human Health for Perfluorooctanoic Acid, Perfluorooctane Sulfonic Acid, and Perfluorobutane Sulfonic Acid (89 Fed. Reg. 105,041-105,043, December 26, 2024) Extension of Reporting Submission Period; Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping Under the Toxic Substances Control Act (TSCA); Change to Submission Period; EPA-HQ-OPPT-2020-0549 Extension request to Methods Update Rule (MUR), December 27, 2024; 21 CFR Part 730 Docket Number FDA-2023-N-4225 Proposed Methods Update Rule (MUR), MUR 22 (90 Fed. Reg. 6,967-7,037, January 21, 2025) 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) 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); 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); 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); implementation of the Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 (P.L. 118-159); U.S.-Mexico water policy; 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); Nationally Determined Contributions (NDCs) under the Paris Climate Accords; DOE Review of Bulk Power Sector Supply Chain Executive Order; environmental, social, and governance (ESG) enforcement; deployment of Smart Water Infrastructure Technology; Border Water Infrastructure Program; Nationwide Permitting Program reissuance; inclusion of American National Standards Institute (ANSI) construction codes in Federal Emergency Management Agency (FEMA) policy; regulation of perfluoroalkyls and polyfluoroalkyl chemicals (PFAS) and fluoropolymers; FERC certification of new interstate gas facilities; Executive Order 14057, Catalyzing Clean Energy Industries and Jobs Through Federal Sustainability, provisions relating to Procurement and PFAS; regulations affecting heavy-duty trucks; potential ban on the use of asbestos; Section 301 exclusions for water filters; Congressional Review Act disapproval of regulations generally; development of legislation following Supreme Court decision limiting agency regulatory deference; Environmental Protection Agency research office generally; Circular No. A-4, Guidance to Federal agencies on the development of regulatory analysis; Conference of the Parties (COP) 28, 29, and 30; endorsement of scientific experts for Integrated Risk Information System (IRIS) assessments; Per- and polyfluoroalkyl substances (PFAS) issues; water and western water issues; water subcabinet; strategic petroleum reserve; reference dose levels for PFOA and PFOS considered by EPAs Science Advisory Board; budget hearings for the Council on Environmental Quality, Environmental Protection Agency; voluntary carbon offset markets; voluntary methane reductions from agriculture/USDA research on methane reductions from agriculture; proposed rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) under interagency review by the Office of Management and Budget (OMB); U.S. Agency for International Development (USAID) Global Water Security Action Plan; Air Quality: Revision to the Regulatory Definition of Volatile Organic Compounds-Exclusion of (2E)-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)); Solid Waste Infrastructure for Recycling Grant Program Request for Information; proposed Clean Water Act Section 401 Water Quality Certification Improvement Rule; EU Methane 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; Waters of the U.S. request for information; petition to EPA to designate solar panels as universal waste; potential reconsideration by EPA of endangerment finding relating to greenhouse gas emissions; 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; DoD PFAS Critical Use Report; Chromium VI SAB hearing; methane mitigation from the natural gas value chain; Office of Information and Regulatory Affairs, Broadening Public Engagement in the Federal Regulatory Process, public hearing and comments; Department of Interior Guidance related to emergency permitting procedures; proposed regulatory determination for PFHxS, HPFO-DA, GenX chemicals, and PFNA; EPAs proposed maximum contaminant levels (MCLs) and proposed maximum contaminant level goals (MCLGs); Clean Water and Drinking Water State Revolving Funds (SRFs); Water and Resilience Provisions (IIJA, P.L. 117-58); Updated Residential Soil Lead Guidance for CERCLA Sites and RCRA Corrective Action Facilities - Docket No. EPA-HQ-OLEM-2023-0644; 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; 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)

Client expense: $19,340,000 · 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 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. 1, One Big Beautiful Bill Act H.R. 33/S. 199, United States-Taiwan Expedited Double-Tax Relief Act H.R. 137, TCJA Permanency Act H.R. 574/S. 187, Accelerate Long-term Investment Growth Now (ALIGN) Act H.R. 684, Protecting American Savers and Retirees Act H.R. 703/S. 213, Main Street Tax Certainty Act H.R. 1062, Growing and Preserving Innovation in America Act of 2025 H.R. 1199/S. 695, Small Business Investment Act of 2025 H.R. 1301/S. 587, Death Tax Repeal Act H.R. 1347/S. 559, American Investment in Manufacturing and Main Street (AIMM) Act H.R. 1801/S. 772, Employer Participation in Repayment Act H.R. 1827/S. 847, Child Care Availability and Affordability Act H.R. 1990, American Innovation and R&D Competitiveness Act of 2025 H.R. 2089/S. 1839, Generating Retirement Ownership through Long-Term Holding H.R. 3512/S. 1821, Tackling Predatory Litigation Funding Act S. 615, Chemical Tax Repeal Act S. 796, Book Minimum Repeal Tax S. 847, Child Care Availability and Affordability Act S. 1443, Mobile Workforce State Income Tax Simplification Act of 2025 S. 1605, International Competition for American Jobs Act S. 1639, American Innovation and Jobs Act S. 1642, Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act H.Con.Res. 14, Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034 H.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Internal Revenue Service relating to Rules for Supervisory Approval of Penalties Draft legislation titled Strengthening Essential Manufacturing and Industrial (SEMI) Investment Act Nomination of Billy Long to be Commissioner of the Internal Revenue Service (IRS) Nomination of Kenneth Kies to be Assistant Treasury Secretary for Tax Policy Proposed Rule, Department of the Treasury, Internal Revenue Service: Excise Tax on Repurchase of Corporate Stock (89 Fed. Reg. 25,980, April 12, 2024) Final Rule, Department of the Treasury, Internal Revenue Service: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income, T.D. 9959, (87 Fed. Reg. 276, January 4, 2022) as corrected by (87 Fed. Reg. 45,018-45,021, July 27, 2022) Proposed Rule, Department of the Treasury, Internal Revenue Service: Rules Regarding Dual Consolidated Losses and the Treatment of Certain Disregarded Payments, (89 Fed. Reg. 64,750, August 7, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Corporate Alternative Minimum Tax Applicable After 2022, (89 Fed. Reg. 75,062-75,243, September 13, 2024) (as corrected by 89 Fed. Reg. 104,909, December 26, 2024) Proposed Rule, Department of the Treasury, Internal Revenue Service: Source of Income from Cloud Transactions (90 Fed. Reg. 3,075-3,085, January 14, 2025) Various issues relating to pension reform; conversion of future 401(k) or Individual Retirement Account (IRA) contributions to Roth accounts; work opportunity tax credit; Canada Digital Services Tax - C-59, An Act to implement certain provisions of the fall economic statement tabled in Parliament; potential modifications to the gasoline tax, including waiving or temporary suspension; implementation of 26 U.S. Code 174 - Amortization of research and experimental expenditures; implementation of the major tax and energy security provisions of the Inflation Reduction Act, (P.L. 117-169); IRS guidance related to the Foreign Tax Credit and the Arms Length Requirement; implementation of the Child and Dependent Care Tax Credit (CDCTC), the Dependent Care Assistance Program (DCAP), and the Employer Provided Child Care Tax Credit (45F); expiration of provisions from the 2017 Tax Cuts and Jobs Act; tax policy priorities for 2025; excise tax on stock buybacks; IRS Notice 2023-64 on Corporate Alternative Minimum Tax Implementation; implementation of the Corporate Transparency Act (CTA) under the National Defense Authorization Act for Fiscal Year 2021; inclusion of Section 45Q - Credit for Carbon Oxide Sequestration under the Inflation Reduction Act of 2022 (P.L. 117-169) in FY25 Budget; Digital Services Taxes (DSTs); expansion of the list of preventive care benefits that may be provided by a high-deductible health plan (HDHP); potential efforts to increase income tax rates; reinstatement of the earnings before interest, tax, depreciation, and amortization (EBITDA) standard for business interest deductions; permanently extending and improving the temporary business, international, and estate tax provisions enacted as part of the 2017 Tax Cuts and Jobs Act, (P.L. No. 115-97); U.S. legislative response to the OECD/G20 Inclusive Framework on Base Erosion and Profit Shiftings two-pillar solution to address the tax challenges arising from the digitalization of the economy; Federal income tax treatment of employer-provided health insurance coverage; challenging the undertaxed profit rule (UTPR) established by Council Directive (EU) 2022/2523 of December 14, 2022; child care related tax credits; dependent care assistance programs; proposals for third party litigation funders to pay tax on their income at the ordinary income tax rate plus a surcharge

Client expense: $19,340,000 · Firm income: Not reported

Government targets: Alcohol & Tobacco Tax & Trade Bureau (TTB), Commerce, Dept of (DOC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), SENATE, Treasury, Dept of, U.S. Trade Representative (USTR)

H.J. Res 27, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Trichloroethylene (TCE); Regulation Under the Toxic Substances Control Act (TSCA);" H.J. Res 76, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Updates to New Chemicals Regulations Under the Toxic Substances Control Act (TSCA);" H.R.1267, Water Systems PFAS Liability Protection Act; H.R.1415, No IRIS Act of 2025; H.R.3110, PFAS-Free Procurement Act; H.R.4016, Department of Defense Appropriations Act, 2026, language related to chemical regulations; H.R.640, Chemical Tax Repeal Act; S.615, Chemical Tax Repeal Act; S.623, No IRIS Act of 2025; S.J.Res.19, A joint resolution providing for congressional disapproval under chapter 8 of Carbon Tetrachloride (CTC), Regulation Under the Toxic Substances Control Act (TSCA); Confirmation hearing for U.S. Environmental Protection Agency Administrator Lee Zeldin; Ethylene Oxide Regulation Formaldehyde and Paraformaldehyde Registration Review Docket; Formaldehyde Regulation; Improvements to the EPA Central Data Exchange (CDX); Make America Healthy Again initiative and report; Perchloroethylene (PCE); Regulation Under the Toxic Substances Control Act (TSCA); Environmental Protection Agency budget and pesticides program; Role of chemical manufactures as a solution provider for EPA's Pillar 5 of Administrator Zeldins Great American Comeback Initiative; Role of chemicals, plastics, and polymer composites in auto safety, lightweighting, energy efficiency and consumer choice; Threshold of Toxicologic Concern (TTC) a New Approach Methodology (NAM); Toxic Substances Control Act implementation U.S. Chemical Safety Board (CSB) value and importance; Unintroduced legislation from Senate of National Defense Authorization Act; Unintroduced legislation of FY2026 Interior, Environment, and Related Agencies, U.S. Environmental Protection Agency; Unintroduced legislation on PFAS; Unintroduced legislation on Toxic Substances Control Act (TSCA); Unintroduced legislation on U.S. Environmental Protection Agencys (EPAs) Science Advisory Board; Using Artificial Intelligence in chemical regulation; U.S. Competitiveness.

Client expense: $4,440,123 · Firm income: Not reported

Government targets: Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, Health & Human Services, Dept of (HHS), SENATE, White House Office

H.R.1, One Big Beautiful Bill Act, tax-related provisions; H.R.640, Chemical Tax Repeal Act; H.R.5376, Inflation Reduction Act of 2022; S.615, Chemical Tax Repeal Act; Business State and local tax exemption; IRA Energy Efficiency Tax Credits 25C, 45L, 179D; IRA energy tax credits 45V, 45Q, and 48C; IRA domestic manufacturing tax credits 48D and 45X; U.S. Competitiveness.

Client expense: $4,440,123 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues related to corporate taxation. H.R. 640/S. 615 - Chemical Repeal Tax Act. H.R. 1 - One Big Beautiful Bill Act.

Client expense: Not reported · Firm income: $100,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General discussions related to corporate taxation including expiration of the Tax Cuts and Jobs Act and the Superfund Tax; S.615/H.R.640, Chemical Tax Repeal Act.

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

General issues related to corporate tax S.615/H.R.640 - Chemical Tax Repeal Act H.R. 1 - One Bill Beautiful Bill Act (OBBBA) reconciliation package, Section 899

Client expense: Not reported · Firm income: $50,000

Government targets: SENATE

General issues related to corporate tax S.615/H.R.640 - Chemical Tax Repeal Act S.1821/H.R.3512 - Tackling Predatory Litigation Funding Act H.R. 1 - One Bill Beautiful Bill Act (OBBBA) reconciliation package

Client expense: Not reported · Firm income: $20,000

Government targets: SENATE

H.R. 26: Protecting American Energy Production Act - provisions of the benefits of responsible energy production through the use of hydraulic fracturing. H.J. Res. 57; Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of the Interior relating to "Oil and Gas and Sulfur Operations in the Outer Continental Shelf-High Pressure High Temperature Updates" - provisions related to the offshore leasing program and efforts to bureaucratically inhibit offshore energy resources through government requirements to the detriment of taxpayers and consumers through higher energy costs. S. 615; Chemical Tax Repeal Act - provisions related to the support of removing arbitrary taxes and penalties on energy producers that result in higher costs for consumers. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the benefits of oil and gas development in the State of Alaska for the permanent fund. Issues related to the negative effects of prematurely removing mineral resources in Federal waters for future energy supply shocks or national security reasons. Issues related to the negative ramifications on commerce for elimination of certain modes of transportation.

Client expense: $305,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.Con.Res.14 - Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034. Senate Amendment to H.Con.Res.14 Issues related to the IRS Direct File Program H.R.1882 - Saving Gig Economy Taxpayers Act S.615 - Chemical Tax Repeal Act S.445 - Carried Interest Fairness Act of 2025 Issues related to the corporate income tax rate

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

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

Infrastructure Investment and Jobs Act (Public Law 117-58); Reinstatement of superfund excise tax on chemicals as a funding mechanism; Implementation. Inflation Reduction Act of 2022 (Public Law 117-169); Incentives for Industrial Decarbonization including Clean Energy Development and Carbon Capture, Utilization, and Storage; Implementation. Tax Cuts and Jobs Act (Public Law 115-97); Expiring provisions H.R.591 - Defending American Jobs and Investment Act Chemical Tax Repeal Act (S.615)

Client expense: $1,670,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Public Law No 117-169: The Inflation Reduction Act of 2022; Corporate taxes and incentives. Extending Tax Cuts & Provisions in Reconciliation Package; R&D Expensing; 163 (j); and Accelerated Depreciation; and potential Pay-fors including 163 (n), corporate tax rate, Corporate SALT. Chemical Tax Repeal Act (S. 615 & H.R. 640), a bill to repeal the excise taxes on certain taxable chemicals and imported substances. Discussion of Product/Manufacturing Essential for Battery Separators, Ultra-High Molecular Weight Polyethylene; Importance of tax credits for global competitiveness such as 45X (Advanced Manufacturing Production Credit). OECD Pillar 2 Guidance; integrity rule and related benefits rule. 45Q Carbon Tax Credit for Sequestration; highlighting benefits for industry investment.

Client expense: $490,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE