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Epa’s Pfas Enforcement Plan Advances as Two Pfas Reporting Requirements Set to Go Into Effect

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On January 6, 2025, the EPA published a final rule adding nine per- and polyfluoroalkyl substances (PFAS) to the Emergency...

We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.

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On January 6, 2025, the EPA published <a href="https://www.federalregister.gov/documents/2025/01/06/2024-31464/implementing-statutory-addition-of-certain-per--and-polyfluoroalkyl-substances-pfas-to-toxics">a final rule</a> adding nine per- and polyfluoroalkyl substances (PFAS) to the Emergency Planning and Community Right-to-Know Act (EPCRA) section 313 list of reportable chemicals (more commonly known as the Toxics Release Inventory (TRI)).Read the full <a href="https://classdismissed.mofo.com/topics/epa-s-pfas-enforcment-plan-advances-as-two-pfas-reporting-requirements-set-to-go-into-effect" target="_blank">blog post</a>.

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Krista deBoer’s practice involves the full range of environmental, climate, and green claims issues.As a partner in MoFo’s Complex Litigation + Advisement practice group, Krista represents clients in environmental and toxic tort litigation, Proposition 65 litigation, and consumer class actions involving hazardous material exposures and claims of health and environmental benefits. She is recommended by The Legal 500 for toxic tort defense (2022-2024). Krista has broad experience in Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and California Hazardous Substance Account Act (HSAA) litigation, multi-party allocation and cost recovery proceedings, natural resource damages claims, and contaminated site cleanup, often involving parallel agency enforcement, where she is skilled at developing integrated strategies to maximize outcomes in both actions.Krista also assists clients with regulatory approvals, compliance, and risk mitigation under federal and state environmental laws, including Department of Energy and California Energy Commission regulations, California Air Resources Board regulations, Federal Trade Commission Green Guides, hazardous waste management regulation, and climate disclosure laws. She has defended and negotiated favorable settlements for clients in enforcement actions brought by the Environmental Protection Agency, California Air Resources Board, California Energy Commission, and California Regional Water Quality Control Boards. In addition, Krista leads environmental due diligence for clients in a range of corporate and real estate transactions involving environmental liability risks and advises on matters involving development of carbon-capture projects and transacting in carbon offsets.Krista has represented and advised aerospace and defense, internet marketplace, food and beverage, importer logistics, healthcare, manufacturing, residential development, energy, transportation, and retail companies.Beyond advocating for clients, Krista also has experience as a mediator and has taught negotiation, advanced negotiation, and difficult conversations seminars to organizations in the United States and abroad, including with the Harvard Negotiation Institute and as an adjunct professor at Georgetown Law School. Krista has a passion for working with clients to design dispute systems and develop persuasive negotiation and communication strategies aimed at achieving optimal outcomes, both within organizations and across the table.Prior to joining Morrison Foerster, Krista practiced at a boutique environmental law firm serving clients in California, Washington, and Oregon, and at an international law firm, where she was a member of the firm’s general litigation and mass tort and environmental practice groups.Krista received her J.D. from Harvard Law School cum laude. At Harvard Law School she was awarded the Dean’s Scholar Prize for her work in the Environmental Law & Policy Clinic and was the president and founding member of the HLS Food Law Society. Krista earned her master’s in education from Antioch University and had a previous career as a public high school teacher. She earned her bachelor’s with honors, magna cum laude, from the University of Washington.

Krista deBoer

Partner

Michael Fine is an associate in the Litigation Department of Morrison Foerster’s Boston office.Michael’s practice focuses on environmental law and policy. Michael regularly advises clients on compliance and risk mitigation under federal and state environmental regulations concerning recyclability, consumer products and packaging, climate disclosures, and green marketing claims.Michael also performs environmental due diligence for clients in a range of corporate and real estate transactions involving environmental liability risks.Before joining Morrison Foerster, Michael was a summer associate at MoFo and served as a judicial intern to the Honorable Michael A. Shipp.Michael received his J.D. magna cum laude from Boston University School of Law. While in law school, he served as diversity & inclusion editor for the Boston University Law Review. Michael received his B.A. in political science and sociology from Rutgers University.