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Sidley Environmental, Health, and Safety Brief
Perspectives for the Environmental, Health and Safety Community
Members of Congress Propose a New Bill to Regulate Autonomous Vehicles
This week, U.S. Representatives Bob Latta and Debbie Dingell released the discussion draft of a new bill: the Safely Ensuring Lives Future Deployment and Research in Vehicle Evolution (SELF DRIVE) Act of 2026. This legislation, if enacted, would be the first federal statute dedicated to the safety of autonomous vehicles. It would have major implications for not only federal, but also state and local regulation. It would also raise some key legal questions and require federal regulators to promulgate a new federal motor vehicle safety standard very different from any of its predecessors. (more…)
Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
New Year, New Packaging Requirements: Extended Producer Responsibility Update
State extended producer responsibility (EPR) programs for packaging materials are no longer on the horizon — as we enter 2026, requirements in some states have already taken effect and more will be implemented this year. Last year, packaging “producers,” including brand owners, manufacturers, distributors, and others saw programs move into operational phases, primarily through a single Producer Responsibility Organization (PRO), the Circular Action Alliance (CAA). Implementation continues across programs in Oregon, Colorado, and California, as well as other states planning to set new requirements. As we begin 2026, covered producers should review these changes and assess the appropriate compliance methodology within their supply chains.
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Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Abigail Kuchnir
Chicago
abigail.kuchnir@sidley.com
The State of Play in California for Autonomous Vehicles
More autonomous vehicles are operating in California than anywhere else in America. And yet California has some of the most extensive autonomous regulations in the country. While some other states have taken a relatively laissez-faire approach to autonomous vehicles, California’s rules are lengthy and elaborate. Even as various operators have been able to work through the requirements to operate in the state, they have been a major lift. And autonomous heavy trucking has been entirely prohibited. (more…)
Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
EPA Memo Emphasizes “Compliance First” Enforcement Approach
On December 5, EPA’s Office of Enforcement and Compliance Assurance (OECA) issued a memorandum to staff affirming a “compliance first” approach to civil enforcement. The memo, signed by Acting Assistant Administrator Craig J. Pritzlaff, applies to all civil enforcement matters and reflects EPA leadership’s instruction to staff regarding inspections, investigations, and enforcement negotiations.
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Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Abigail Kuchnir
Chicago
abigail.kuchnir@sidley.com
Department of Transportation Proposes Dramatic Rollback of Corporate Average Fuel Economy (CAFE) Standards
On December 3, in connection with a highly publicized announcement in the Oval Office and a statement from the White House, the Department of Transportation proposed a rulemaking that would reset Corporate Average Fuel Economy (CAFE) standards for passenger cars and light trucks sold in the United States for model years 2022-2031. Along with Congress’s recent elimination of civil penalties for CAFE noncompliance, the proposal would roll back more stringent fuel economy targets set in previous Administrations—including the first Trump Administration. The proposed changes have significant implications for, among other things, the electric vehicle market.
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Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
Open for Business: A Look at NHTSA Auto Safety Investigations in the Second Trump Administration
The second Trump administration has seen drastic changes in the enforcement practices of many federal regulatory agencies. One area where investigative activity continues to be robust is auto safety. The National Highway Traffic Safety Administration (NHTSA) has, in, recent months, been opening investigations at a brisk pace. Some of NHTSA’s work, particularly relating to autonomous operations and counterfeit equipment, has attracted substantial public attention. Other investigations have been more business as usual.
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Adam M. Raviv
Washington, D.C.
adam.raviv@sidley.com
FWS and NMFS Propose Four Rules Overhauling ESA Implementation: Greater Emphasis on Species-Specific Analysis, Economic Impacts, and Critical Habitat Exclusions
On November 21, 2025, the U.S. Fish and Wildlife Service (FWS) and National Marine Fisheries Service (NMFS) (collectively, the Services) have issued a coordinated package of four proposed rules that would significantly revise how the Endangered Species Act (ESA) is implemented. [1] Two of the rules apply to both agencies, and two are FWS-only. Together, the proposals would shift ESA implementation toward a more species-specific, economically informed, and text-focused framework, with important implications for energy, infrastructure, and land-use projects.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Riley Desper
Washington, D.C.
EPA and Army Corps Propose to Narrow Federal Jurisdiction Under the Clean Water Act
On Monday, November 17, 2025, the U.S. Environmental Protection Agency (EPA) and U.S. Army Corps of Engineers (Corps) (collectively, the “Agencies”) released a pre-publication proposed rule to revise the definition of “Waters of the United States” (WOTUS) under the Clean Water Act (CWA). The proposal responds to the U.S. Supreme Court’s 2023 decision in Sackett v. EPA, 598 U.S. 651 (2023), but goes further than the Biden Administration’s response to the Sackett ruling in August 2023 (the “Conforming Rule”).[1] Sidley’s blog post on the prior administration’s rule can be found here.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Caleb J. Bowers
Los Angeles
cbowers@sidley.com
Riley Desper
Washington, D.C.
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Samuel B. Boxerman
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Keturah A. Brown
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