The proposed rule would scale back federal jurisdiction under the Clean Water Act.

By Nikki Buffa, John C. Heintz, Michael G. Romey, Jennifer K. Roy, Lucas I. Quass, and Samantha Yeager

On November 17, 2025, the United States Environmental Protection Agency (EPA) and the Department of the Army, Corps of Engineers (USACE) (together with EPA, the Agencies) announced a proposed rule that would revise the definition of “waters of the United States” (WOTUS) under the

The rule positions the Railroad Commission of Texas as the primary permitting authority over Class VI wells and could expedite CCS projects in the state.

By Joshua T. Bledsoe, Nikki Buffa, Jennifer K. Roy, Nolan Fargo, and Samantha Yeager

The US Environmental Protection Agency (EPA) has approved Texas’s application to assume primary enforcement responsibility, or “primacy,” for Class VI underground injection control (UIC) wells within the state. Class VI UIC wells are used for the permanent

California Governor Gavin Newsom signed legislation lifting moratorium on transportation of carbon dioxide by pipeline.

By Joshua T. Bledsoe, Marc T. Campopiano, Brian McCall, and Shawna Strecker

On October 10, 2025, Governor Gavin Newsom signed legislation aimed at boosting California’s carbon capture, removal, utilization and storage (CCUS) market. CCUS involves capturing carbon dioxide (CO2) from point-sources — such as industrial facilities — transporting it, and injecting it into underground geological formations for permanent storage, enhanced oil recovery

With the new proposal, EPA seeks to limit the reporting burden on the chemical industry.

By Julia A. Hatcher, Tom Lee, and Hunter J. Kendrick

On November 10, 2025, the US Environmental Protection Agency (EPA) released its much anticipated proposed changes to what is often referred to as the “8(a)(7) Rule” that requires businesses to report on the manufacture and import of certain per- and polyfluoroalkyl substances (PFAS).1 As the name suggests, the rule derives from

New statute allows the government to recover costs and natural resource damages from a broad set of PRPs.

By Gary P. Gengel, Thomas C. Pearce, G. Jack Mathews, and Gina Kwon

On May 9, 2025, New York Governor Kathy Hochul signed into law a broad array of amendments to the state’s Environmental Conservation Law sections pertaining to the Inactive Hazardous Waste Disposal Site program, also known as the state Superfund program (the Amendments). The Amendments address (1)

The agency simultaneously issued a survey to validate the list.

By Joshua T. Bledsoe, Nikki Buffa, Betty M. Huber, Austin J. Pierce, and Shawna Strecker

On September 24, 2025, the California Air Resources Board (CARB) published a list of entities that it believes will be subject to requirements under Senate Bill (SB) 253 and/or SB 261. The list serves as an initial reference point for companies with a nexus to California regarding their reporting obligations. CARB