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Sidley Environmental, Health, and Safety Brief
Perspectives for the Environmental, Health and Safety Community
EPA Proposes Exemptions to TSCA PFAS Reporting Rule
On November 13, 2025, the U.S. Environmental Protection Agency (EPA) published a proposed rule that would revise the scope of EPA’s Toxic Substances Control Act (TSCA) Section 8(a) rule requiring a one-time expansive data submission on per- and polyfluoroalkylated substances (PFAS Reporting Rule). The proposal introduces several exemptions designed to reduce compliance costs and improve implementation. The revisions aim to make the one-time PFAS reporting requirements more practical, particularly for small manufacturers and importers, while preserving EPA’s access to use and exposure information. EPA will accept public comments until December 29, 2025.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Brittany A. Bolen
Washington, D.C.
bbolen@sidley.com
Riley Desper
Washington, D.C.
Leena Dai
Washington, D.C.
leena.dai@sidley.com
New York Court Orders NYDEC to Issue Climate Change Regulations by February 2026
On October 24, 2025, a New York trial court ordered the New York Department of Environmental Conservation (NYDEC) to promulgate regulations addressing climate change pursuant to the state’s 2019 Climate Leadership and Community Protection Act, 2019 N.Y. Sess. Laws Ch. 106 (S. 6599) (CLCPA). The court sided with environmental groups that argued that NYDEC’s failure to issue these rules violated a mandatory statutory duty, despite the agency’s arguments that such rules would be “infeasible” because of costs imposed on consumers. With the order requiring promulgation of the rules by February 6, 2026—mere months away—stakeholders should watch closely for details on upcoming compliance requirements.
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Leena Dai
Washington, D.C.
leena.dai@sidley.com
The Trump Administration’s Pushback Against a Global Shipping Carbon Levy
The International Maritime Organization (IMO), the United Nations agency tasked with regulating global shipping, has proposed an international carbon pricing scheme on shipping. The maritime shipping sector has increasingly faced global scrutiny as the contributor of 3% of global greenhouse gas emissions, and IMO’s proposed mechanism would serve as the first global emissions pricing mechanism affecting the shipping sector.
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Abigail Kuchnir
Chicago
abigail.kuchnir@sidley.com
Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
OMB’s Office of Information and Regulatory Affairs Issues New Guidance to Accelerate Deregulatory Actions
On October 21, the Office of Information and Regulatory Affairs (OIRA) in the White House Office of Management and Budget (OMB) issued a memorandum aimed at providing guidance for “Streamlining the Review of Deregulatory Actions” to federal agencies. The guidance follows recent Executive Orders (EOs) and a Presidential Memorandum issued earlier in the Trump Administration that emphasized the Administration’s focus on deregulation as a driver of economic growth and government efficiency.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Brittany A. Bolen
Washington, D.C.
bbolen@sidley.com
Lauren E. DeCarlo
Chicago
lauren.decarlo@sidley.com
Governors of PJM States Intensify Pressure on PJM for Reform
A bipartisan group of governors of PJM Interconnection (PJM) member states has intensified calls for reforming PJM after what they have described as a “crisis of confidence,” citing high electricity prices, interconnection delays, and lack of transparency and state participation in the RTO’s decision-making processes.
Terence T. Healey
Boston
thealey@sidley.com
Priya Kareddy
Washington, D.C.
priya.kareddy@sidley.com
Tanner L. Groce
Houston
tgroce@sidley.com
Council on Environmental Quality Issues Long Awaited Guidance for Environmental Review Across Agencies
On September 29, 2025, the Council on Environmental Quality (CEQ) issued long-awaited guidance to formalize agencies’ individual efforts to implement the National Environmental Policy Act (NEPA). After rescinding the CEQ regulations that shaped NEPA for 40+ years and bearing witness to various agencies’ independent efforts to issue their own NEPA rules, CEQ issued new guidance to more systematically guide the agencies’ efforts. As CEQ notes, “NEPA implementation reform now has been called for, authorized, and directed by all three branches of government at the highest possible level: Congress, the President, and the Supreme Court.” The guidance reflects direction from each.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Peter Whitfield
Washington, D.C.
pwhitfield@sidley.com
Brooklyn Hildebrandt
Los Angeles
bhildebrandt@sidley.com
EPA, Departments of Interior and Energy Announce New Coal-Friendly Policy Initiatives
On September 29, 2025, the Trump Administration unveiled a sweeping set of policy initiatives aimed at revitalizing the U.S. coal sector that spans multiple federal agencies and includes measures such as increased funding and financial incentives, relief from environmental regulatory requirements, and increased access to public lands. In the unveiling, the Administration emphasized the importance of American “energy dominance” and the increased demand for electricity to power artificial intelligence (AI) in order to ensure that the United States wins “the AI arms race” — two themes commonly highlighted by the Administration and its top officials.
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Samuel B. Boxerman
Washington, D.C.
sboxerman@sidley.com
Rose Quam-Wickham
Washington, D.C.
rquamwickham@sidley.com
Interconnection Reform Critical to the Efficiency of Energy Markets
The U.S. power grid is undergoing a period of rapid change, with federal agencies such as the Department of Energy (DOE) and the Federal Energy Regulatory Commission (FERC) initiating programs and regulatory actions to address the integration of new generation and transmission resources. According to a recent DOE report, the U.S. grid is facing the retirement of 104 GW of firm capacity (generation that can operate continuously) by 2030, and the planned addition of 209 GW of new generation in the same period. The White House is concerned that the retirement of “baseload” power plants will impede President Trump’s economic goals; as such, press reports say that the administration is expected to issue new emergency orders preventing fossil fuel plants from retiring.
Kenneth W. Irvin
Washington, D.C.
kirvin@sidley.com
Tiph Kugener
Houston
tiphaine.kuegner@sidley.com
Evan Grosch
Houston
egrosch@sidley.com
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Samuel B. Boxerman
sboxerman@sidley.com
Keturah A. Brown
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Grace Dickson Gerbas
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Terence T. Healey
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Kenneth W. Irvin
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Casey Khan
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Michael L. Lisak
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Brittany A. Bolen
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Brooklyn Hildebrandt
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Nicole E. Noëlliste
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Hannah Posen
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Jack Raffetto
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