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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.

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