
Charles J. Dennen
Partner
Overview
Representative Experience
News & Insights
12.02.2025
Articles
EPA Proposes Significant Changes to PFAS Reporting Requirements Under the TSCA
In an article for The Legal Intelligencer, partner Charlie Dennen writes about the U.S. Environmental Protection Agency’s (EPA) proposed significant changes to PFAS reporting requirements under the Toxic Substances Control Act (TSCA). These updates aim to simplify compliance and reduce costs for manufacturers and importers. Key proposals include exemptions for low-concentration PFAS in mixtures, imported articles, and byproducts, as well as research and development chemicals. The rule also shortens the data submission period and removes reporting requirements for small manufacturers. These changes are expected to save industry up to $843 million in compliance costs. The EPA is seeking public input on the proposed changes until December 29, 2025, particularly regarding the exemptions and the amended data submission timeline.
09.17.2025
Client Advisories
USEPA Announces Proposal to End Greenhouse Gas Reporting Program
On September 12, 2025, the United States Environmental Protection Agency (USEPA) formally announced a proposed rule to end the Greenhouse Gas Reporting Program (GHGRP). The GHGRP applies to 47 source categories and covers approximately 8,000 facilities throughout the United States, requiring power plants, refineries, chemical plans, fossil fuel and industrial gas suppliers, and carbon dioxide injection sites to report greenhouse gas emission data on an annual basis.
09.08.2025
Articles
EPA's Proposal to Rescind 2009 Endangerment Finding and the Impact of 'Loper Bright'
The EPA has proposed rescinding its 2009 “endangerment finding,” the foundation for federal greenhouse gas regulations. The agency argues that the Supreme Court’s 2024 decision in Loper Bright v. Raimondo, which overturned the long-standing Chevron doctrine, undermines the legal basis for the finding.