NHTSA Delays Implementing Updates to the Five-Star Safety Ratings Program (NCAP)
On September 22, the National Highway Traffic Safety Administration (NHTSA) published a notice delaying by one year the upcoming implementation date for two recent updates to the agency’s New Car Assessment Program (NCAP). This change illustrates NCAP’s continuing importance to manufacturers and NHTSA’s recent willingness to push back the compliance dates of completed rulemakings. (more…)
EPA Proposes Revisions to TSCA Risk Evaluation Framework for Existing Chemicals
On Tuesday, September 23, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule to revise its procedural framework for conducting risk evaluations for chemicals already in commerce under the Toxic Substances Control Act (TSCA) (Proposed Framework Rule). The purpose of risk evaluation is to determine whether an existing chemical substance presents an unreasonable risk to health or the environment, under the conditions of use. Risk evaluation is the second step in EPA’s existing chemical process under TSCA, before EPA develops and proposes a rule to manage any such unreasonable risks.
EPA Proposes Overhaul of Greenhouse Gas Reporting Program
On September 16, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would fundamentally reshape the federal Greenhouse Gas Reporting Program (GHGRP). 90 Fed. Reg. 44591 (Sept. 16, 2025). If finalized, this action would mark a further shift in federal greenhouse gas (GHG) policy and advance the administration’s broader deregulatory agenda.
Texas Rising: Texas’ Rise as a Premier Domicile
While Delaware has long been regarded as the gold standard for corporate domiciles, boasting a well-established body of corporate law and a highly specialized Court of Chancery, the State of Texas has rapidly been working to close the gap.[1] This momentum has been sustained by the State’s statutory framework, practiced judicial restraint, and numerous socioeconomic incentives that come with operating in Texas. (more…)
Trump EPA Releases First Regulatory Agenda of Second Term – Key Takeaways and Timelines
The Trump Administration’s Spring 2025 Unified Agenda underscores the EPA’s central role in reshaping federal regulations. From PFAS standards to greenhouse gas rules and permitting reforms, the agenda highlights rollbacks of climate-related measures while introducing new compliance timelines. Companies should prepare now to engage on rules that will directly impact operations in energy, manufacturing, and beyond.
D.C. Circuit Restores Emergency Affirmative Defense for Title V Permit Holders
The D.C. Circuit recently reversed EPA’s rescission of a 1990s rule that established an emergency affirmative defense under the Clean Air Act for Title V permit holders that exceed an emission limitation due to an emergency. Our team breaks down what this means for facilities facing unexpected emissions exceedances.
The Department of Transportation’s Spring 2025 Regulatory Agenda: Big Announcements on Autonomous Vehicles and Automatic Emergency Braking
On September 4, 2025 the National Highway Traffic Safety Administration (NHTSA) announced several planned rulemakings relating to autonomous driving systems as part of the Trump Administration’s Spring 2025 regulatory agenda. The Secretary of Transportation said: “The rules of the road need to be updated to fit the realities of the 21st century. Our changes will eliminate redundant requirements and bring us closer to a single national standard that spurs innovation and prioritizes safety.” The Department of Transportation’s regulatory agenda also has dozens of other items, including two notable actions on automatic emergency braking.
