Significant Changes on the Horizon to the Limitations on Subcontracting
Client Alert | less than 1 min read | 01.14.15
On December 29, 2014, the Small Business Administration issued long overdue proposed amendments to its regulations (with 60 days for comments) to implement many of the provisions of the National Defense Authorization Act of 2013, most notably with a complete overhaul of the calculation of the limitations on subcontracting. Additional proposed revisions include: greater specificity to the identity of interest affiliation test; exemptions from affiliation for small business joint venture members and "similarly situated" subcontractors; a new recertification requirement for mergers/acquisitions occurring after proposal submission but prior to award; changes to the nonmanufacturer rule; and a new reporting mechanism and expanded sanctions related to subcontracting plan compliance.
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Client Alert | 3 min read | 05.28.26
Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program.
Client Alert | 8 min read | 05.28.26
Texas Targets Big Tech With Wave of Suits and Investigations, Part of Nationwide Trend
Client Alert | 7 min read | 05.27.26
Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act
Client Alert | 3 min read | 05.27.26
Don’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to Intervene
