FTA Proposes Requiring 100% U.S.-Origin Components for Rolling Stock Overhauls
Client Alert | 1 min read | 05.31.12
To "reclarify" an issue the Federal Transit Administration (FTA) thought it had settled in its 2007 rulemaking, on May 21, 2012, the FTA provided notice (with opportunity to comment on or before June 20, 2012) of its interpretation that the statutory exception permitting acquisition of rolling stock with only 60% U.S.-origin components did NOT apply to overhauls, because overhauls are more akin to replacement and repairs. Engine rebuilds, on the other hand, which extend the useful life of the rolling stock, would continue to qualify for the reduced level of domestic content (but also subject, presumably, to the requirement that 60% of the subcomponents used in a rebuild must be U.S.-origin for the component to qualify as domestic).
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Client Alert | 5 min read | 08.26.26
D.C. Circuit Upholds Designation of PFOA and PFOS as CERCLA Hazardous Substances
In a significant and unanimous ruling, the D.C. Circuit upheld the Environmental Protection Agency’s (“EPA”) final rule designating perfluorooctanoic acid (“PFOA”) and perfluorooctanesulfonic acid (“PFOS”) as “hazardous substances” under the Comprehensive Environmental Response, Compensation, and Liability Act (“CERCLA”), denying the petitions of seven industry groups seeking to overturn that designation.[1] CERCLA, also known as the “Superfund Statute,” allows EPA to require potentially responsible parties to fund cleanup of hazardous substances.
Client Alert | 5 min read | 08.26.26
Client Alert | 6 min read | 08.26.26
The Risky Fifth: A Long Hot Summer in Congressional Jurisprudence
Client Alert | 4 min read | 08.25.26
DOJ Signals Increased Antitrust Scrutiny of Algorithmic Pricing in Willow Bridge Decision
