BPAs: They Ain't Contracts
Client Alert | less than 1 min read | 02.14.14
In Crewzers Fire Crew Transport, Inc. v. U.S. (Feb. 6, 2014), the Federal Circuit reaffirmed that a blanket purchase agreement is not typically a binding contract on which the contractor can sue. In this instance, as in many, the necessary "mutuality of obligation" was negated in both directions, with the BPA expressly saying the agency was not obligated to make an award under the BPA and that the contractor was not obligated to accept any order proffered by the agency.
Contacts
Insights
Client Alert | 3 min read | 05.16.25
On May 14, 2025, the Environmental Protection Agency (“EPA”) announced that it will keep the current National Primary Drinking Water Regulations (“NPDWR”) for perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonic acid (“PFOS”) under the Safe Drinking Water Act (“SDWA”), while extending the compliance deadline from 2029 to 2031. EPA further announced it plans to rescind requirements in those regulations applicable to other PFAS and mixtures of certain PFAS in drinking water. The NPDWR consists of legally enforceable primary standards and treatment techniques that apply to public water systems and guide EPA’s enforcement of the SDWA. This announcement follows EPA’s April 28, 2025 press release outlining its priorities for PFAS enforcement, which included 21 actions EPA intends to take to address PFAS and “engage with Congress and industry to establish a clear liability framework that ensures the polluter pays and passive receivers are protected.”
Client Alert | 2 min read | 05.16.25
Client Alert | 3 min read | 05.16.25
New SF-328 Released and Embedded Guidance Seeks More Information Up Front
Client Alert | 6 min read | 05.16.25
Recent Antitrust Enforcer Statements Signal New Administration’s Direction and Priorities
