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New Executive Compensation Limits

Client Alert | 1 min read | 06.28.13

On June 26, 2013, the government issued an interim rule that purports to expand the application of the executive compensation benchmark, currently set at $763,029, from senior executives to all contractor employees performing on contracts awarded as of December 31, 2011, by DoD, NASA, and the Coast Guard. As discussed in our blog posting, this interim rule, which is effective immediately, is intended to make any compensation costs incurred after January 1, 2012, over the benchmark amount unallowable for contracts subject to the FAR cost principles, but challenges to this rule based on the terms of the Allowable Cost and Payment clause might result.


Insights

Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

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Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the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....