Author: Sharon Newlon

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Michigan Court of Appeals Strikes State PFAS Drinking Water Standards

On August 22, 2023, a split panel of the Michigan Court of Appeals held that the Department of Environment, Great Lakes, and Energy (EGLE) violated the Administrative Procedures Act (APA) by promulgating a new rule establishing drinking water standards for seven PFAS[1] compounds. The required regulatory impact statement (RIS) did not consider compliance costs associated …

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U.S. EPA Proposed Listing of PFOA and PFOS: The Effects and Costs of Forever Chemicals

On September 6, 2022, the U.S EPA’s long-awaited proposed rule to list perfluorooctanoic acid (PFOA) and perluoroocanesulfonic acid (PFOS) as CERCLA hazardous substances was published in the Federal Register (Proposed Rule).[1]  This triggers a 60-day public notice and comment period. As the first compounds ever proposed for hazardous substance listing under Section 102(a) of CERCLA, …

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