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I am a Partner in the Environmental, Energy + Telecommunications Group. My practice focuses on assisting clients in complying with federal and state environmental laws, with a particular focus on the management of hazardous and toxic substances, especially under the Toxic Substances Control Act an the Emergency Planning and Community Right-to-Know Act. I also regularly help clients understand, manage, and limit environmental risk associated with business and property transactions, including assisting clients in complying with transaction-triggered compliance requirements like the Connecticut Transfer Act. My full bio is here.

On May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced an amendment delaying the data submission period for the Toxic Substances Control Act (TSCA) PFAS reporting rule, which will now begin on April 13, 2026, and end on October 13, 2026. Small manufacturers who report solely as article importers will have until April 13

The U.S. Environmental Protection Agency (EPA), under Administrator Lee Zeldin, has unveiled its anticipated strategy for addressing the pervasive issue of per- and polyfluoroalkyl substances (PFAS), often referred to as “forever chemicals.” While the announcement provides a broad framework, specific details (particularly regarding potential changes to previous rulemakings under CERCLA and the Safe Drinking Water

For the last 40 years, the Connecticut Transfer Act has primarily driven the remediation of contaminated property in Connecticut—this will change early next year.

Currently, the Connecticut Transfer Act (Conn. Gen. Stat. § 22a-134 et seq.) requires site-wide investigation, and potential remediation, upon the “transfer” of an “establishment” as defined by the Transfer Act.

Last week EPA released its proposal for the first set of Maximum Contaminant Levels (MCLs) under the Clean Water Act for per- and polyfluoroalkyl substances (PFAS).  In contrast to non-enforceable health advisory levels introduced in 2016 and revised in 2022, MCLs constitute enforceable drinking water standards that will impact drinking water utilities and industry nationwide. 

Last week, the U.S. Environmental Protection Agency (EPA) released a pre-publication version of a Proposed Rule to designate PFOA and PFOS as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA or Superfund).  This marks the next step in a trend of increasing regulation of per- and polyfluoroalkyl substances (PFAS), a class

On October 22, 2021, EPA published a proposed rule that would, if adopted, provide a significantly enhanced additional pathway for remediation of sites impacted by polychlorinated biphenyls or PCBs. EPA helpfully included a redline version showing proposed changes to the regulatory text. EPA is receiving comments on the proposed rule until December 21, 2021.

PCBs