SB 54 Regulations Public Comment Period Open Until June 3, 2025

CalRecycle has released amendments to the proposed regulations implementing California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act (SB 54) and published its Report to the Legislature describing the program’s broader implementation. CalRecycle is accepting public comments on the proposed changes to the regulations through tomorrow, June 3, 2025.

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OSHA Updates Site-Specific Targeting Program Based on Injury/Illness Rates: What Employers Should Know

On May 20, 2025, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced an updated directive to its Site-Specific Targeting (SST) inspection program. This program is OSHA’s primary mechanism for scheduling planned inspections at non-construction establishments with 20 or more employees.

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EPA Advances State Primacy for Underground Injection Control Class VI Well Programs: Key Updates for Carbon Sequestration Efforts

The U.S. Environmental Protection Agency (EPA) continues to take steps to expand state primacy for the Underground Injection Control (UIC) Class VI well program, established under the Safe Drinking Water Act (SDWA). Class VI wells, added as a distinct category in 2010, are used to inject carbon dioxide into deep rock formations for the purpose of long-term geologic carbon sequestration.

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U.S. Environmental Protection Agency Extends PFAS Reporting Rule Submission Period

On Monday, May 12, 2025, the U.S. Environmental Protection Agency (EPA) announced an interim final rule to extend the reporting period for the EPA’s rule requiring data submission on per- and polyfluoroalkylated substances (PFAS Reporting Rule).

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U.S. Environmental Protection Agency Announces New PFAS Action Plan

On April 28, 2025, U.S. Environmental Protection Agency (EPA) Administrator Lee Zeldin announced the Agency’s plan to address per- and polyfluoroalkyl substances (PFAS) during the second Trump Administration. PFAS are manmade chemicals—of which there are thousands—commonly found in textiles, cookware, packaging, plastics, and firefighting foams. These “forever chemicals” are persistent in the environment and human body, as they do not break down and can accumulate over long periods of time. EPA’s outlined action plan calls upon its investigatory, regulatory, and enforcement powers under various statutes, including the Toxic Substances Control Act (TSCA), Clean Water Act (CWA), Safe Drinking Water Act (SDWA), Resource Conservation and Recovery Act (RCRA), and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

Department of the Interior Accelerates Permitting for Oil and Gas, Adopts 28-Day Mandate

In response to the Trump administration’s push to increase U.S. energy output by declaring a national energy emergency, the Department of the Interior (the Interior) has released plans to aid the administration’s goals.  These include the Interior’s Emergency Permitting Procedures intended to accelerate and streamline review and approval of certain energy projects, primarily oil and gas.  Bypassing formal rulemaking, the Interior cites its authority during emergencies to implement “alternative processes” to comply with the National Environmental Policy Act (NEPA), the National Historic Preservation Act (NHPA), and the Endangered Species Act (ESA).  The alternative processes are available to current and future applicants so long as they affirm in writing to the Interior that they qualify for and want to avail themselves of the expedited processes.

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NHTSA Announces New Policies to Promote Autonomous Vehicles

On April 24, 2025, the Department of Transportation announced the new Automated Vehicle (AV) Framework from the National Highway Traffic Safety Administration (NHTSA).  The announcement, which was accompanied by a video from the Secretary of Transportation, included two new policy developments.  First, NHTSA released a Third Amended version of its Standing General Order on Automated Driving Systems (ADS) and Advanced Driver Assistance Systems (ADAS).  Second, NHTSA announced that it would expand its exemption program for autonomous vehicles that do not fully comply with NHTSA’s Federal Motor Vehicle Safety Standards.  This update discusses both developments and their broader implications.

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Fish and Wildlife Revives Incidental Take Saga Under the Migratory Bird Treaty Act

In latest saga surrounding the formidable Migratory Bird Treaty Act (MBTA or Act), the U.S. Fish and Wildlife Service on April 21, 2025, withdrew its 2021 advance notice of proposed rulemaking to potentially authorize the incidental taking or killing of migratory birds, consistent with its interpretation of the Act.  The 2021 advance notice promised a new regulatory scheme possibly authorizing the incidental take of migratory birds — a practice that would have broken with pre-2017 MBTA interpretation but more practically implement the Act in response to various needs, such as infrastructure permitting and development.

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<a target=‘_blank’ href="https://www.sidley.com/en/people/b/boxerman-samuel-b">Samuel B. Boxerman</a>

Samuel B. Boxerman

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/b/brown-keturah-a">Keturah A. Brown</a>

Keturah A. Brown

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/d/dickson-gerbas-grace">Grace Dickson Gerbas</a>

Grace Dickson Gerbas

Dallas
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/healey-terence-t">Terence T. Healey</a>

Terence T. Healey

Boston
<a target=‘_blank’ href="https://www.sidley.com/en/people/i/irvin-kenneth-w">Kenneth W. Irvin</a>

Kenneth W. Irvin

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/polito-christopher-j">Christopher J. Polito</a>

Christopher J. Polito

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/k/khan-casey">Casey Khan</a>

Casey Khan

Houston
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/lisak-michael-l">Michael L. Lisak</a>

Michael L. Lisak

Chicago
<a target=‘_blank’ href="https://www.sidley.com/en/people/b/bolen-brittany-a">Brittany A. Bolen</a>

Brittany A. Bolen

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/hildebrandt-brooklyn">Brooklyn Hildebrandt</a>

Brooklyn Hildebrandt

Los Angeles
<a target=‘_blank’ href="https://www.sidley.com/en/people/n/noelliste-nicole-e">Nicole E. Noëlliste</a>

Nicole E. Noëlliste

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/p/posen-hannah">Hannah Posen</a>

Hannah Posen

Chicago
<a target=‘_blank’ href="https://www.sidley.com/en/people/r/raffetto-jack-c">Jack Raffetto</a>

Jack Raffetto

Washington, D.C.

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