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Environmental Compliance + Permitting

Manufacturers, property owners, and developers turn to our Environmental Compliance + Permitting practice group for legal advice on all regulatory issues. We identify effective strategies that address regulatory requirements, as well as physical and operational limitations and other competing factors that affect compliance and permitting efforts.

Our Services

Our lawyers offer a range of legal services, from serving as active members of corporate compliance teams and auditing efforts to representing applicants in state and federal permit proceedings. We provide the legal analysis and support our clients need for the range of regulatory programs they face. These issues include federal programs and their state and local counterparts, including:

  • Clean Water Act
  • Oil Pollution Act
  • Clean Air Act
  • Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA)
  • Emergency Planning and Community Right-to-Know Act (EPCRA)
  • Occupational Safety and Health Act (OSHA) and Mine Safety and Health Act (MSHA)
  • Resource Conservation and Recovery Act (RCRA)
  • Toxic Substances Control Act (TSCA)

Through our deep understanding of these programs, we provide clients with effective advice and representation on preventive measures and corrective actions for their environmental, health, and safety concerns, including:

  • Air emissions
  • Cleanup, remediation, and other release and emergency response actions
  • Financial assurance
  • Oil and chemical release planning and prevention
  • Spill and safety reporting
  • Solid and hazardous waste
  • Stormwater runoff and sedimentation controls
  • Underground storage tank systems
  • Wastewater discharges
  • Worker safety measures
  • Abatement of asbestos, polychlorinated biphenyls (PCBs), and other building material constituents

Our Team

Our Environmental Compliance + Permitting team participates in and often leads the latest discussions and legal changes affecting our clients, —including new and emerging efforts to address sustainability and climate change. We closely attend to the expanding reach of toxic and chemical substance regulations, such as those being developed and implemented under the Frank R. Lautenberg Chemical Safety for the 21st Century Act, California’s Proposition 65, EPCRA, the European Union’s Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) program, and TSCA.

Our Environmental Compliance + Permitting attorneys draw on experience gained from representing a diverse range of clients and industries. Several members of our team also have science and engineering degrees, and formerly held positions in federal, state, and local environmental agencies.

Whether you are a manufacturer, property owner, or developer, our Environmental Compliance + Permitting practice group has the insights and experience to help you navigate the regulatory issues impacting your business. Our legal services will help you manage compliance-related risk and achieve related strategic objectives.

Experience

Fuel Oil Terminal Conversion

Represented a waterfront fuel oil terminal owner in the investigation, negotiation of alternative clean standards, remediation, and structuring of transaction to sell and convert the terminal to upscale residential apartments.

R+C Preferred Counsel for United Technologies Corporation on Environmental, Health, and Safety Matters

Serving as national preferred counsel for United Technologies Corporation on environmental, health, and safety matters, Robinson+Cole provides strategic advice and representation on issues arising under RCRA, CWA, CAA, CERCLA, EPCRA, OSHA, TSCA and many other state and federal EH+S laws affecting UTC Corporate Headquarters, UTC Aerospace Systems, Pratt & Whitney, Otis Elevator, Carrier, and UTC Climate, Controls & Security business units.

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Critical Input Provided to Institutional Investor's Due Diligence and Renovation Plans

Provided critical input to institutional investor’s due diligence and renovation plans for a large city office building by analyzing impacts under TSCA from polychlorinated biphenyls (PCBs) detected in window caulking.

Publications

Vol. 10.1

New UST Requirements (and Potential "Buried Hazards") in Connecticut Revised Underground Storage Tank Regulations

CEMA Aegis
Legal Update: EPA Issues COVID-19 Enforcement Discretion Policy teaser
March 31, 2020

Legal Update: EPA Issues COVID-19 Enforcement Discretion Policy

July 2015

Unseen risks: New EPA vapor intrusion guide for leaking petroleum underground storage tank sites

Vol. 10.1

New UST Requirements (and Potential "Buried Hazards") in Connecticut Revised Underground Storage Tank Regulations

CEMA Aegis
Legal Update: EPA Issues COVID-19 Enforcement Discretion Policy teaser
March 31, 2020

Legal Update: EPA Issues COVID-19 Enforcement Discretion Policy

July 2015

Unseen risks: New EPA vapor intrusion guide for leaking petroleum underground storage tank sites

News

September 10, 2025

Robinson+Cole Environmental Partner Hosts New Video Podcast Series Sharing Insights on Connecticut’s Release-Based Cleanup Regulations

Robinson+Cole’s Environmental Law + blog has launched a new video podcast series, The Release Report: Inside Connecticut’s Release-Based Cleanup Regulations. The series is hosted by Environmental partner Emilee Mooney Scott, a member of the Working Group convened under Public Act 20-09, which initiated the transition from the state's transaction-based Transfer Act to a Release-Based Cleanup Regulation (RBCR). Scott brings deep insight into the regulatory changes reshaping Connecticut’s environmental landscape. The Release-Based Cleanup Regulations, set to take effect on March 1, 2026, will replace the longstanding Transfer Act, which has governed environmental cleanup in the state for nearly four decades. Through The Release Report series, Scott will guide blog viewers and readers through the steps required under the new regulations—from discovery and reporting of releases to cleanup and closure—highlighting the implications for property transactions, redevelopment, and commercial and industrial operations across the state. “This video podcast series will explore how these new regulations will replace the longstanding Transfer Act,” said Scott. “I will provide valuable and in-depth insights on these new regulations, shedding light on the opportunities and challenges they present for stakeholders, so that they are well-prepared for the future of Connecticut's environmental landscape.” “The Release Report reflects Robinson+Cole’s commitment to providing timely, practical insights on the evolving regulatory landscape in Connecticut,” said James P. Ray, chair of the firm’s Environmental, Energy + Telecommunications group. “Emilee’s deep involvement in the development of the Release-Based Cleanup Regulations and her ability to translate complex policy into actionable guidance make this series an invaluable resource for our clients and the broader business and real estate community.” About the Host: Emilee Mooney Scott Emilee Mooney Scott is a recognized authority on Connecticut’s environmental regulations and a driving force behind the transition to a Release-Based Cleanup Framework. Scott was appointed to the Working Group jointly convened by the Connecticut Department of Energy and Environmental Protection and the Department of Economic and Community Development under Public Act 20-9 to advise on Connecticut’s release-based environmental investigation and remediation program. Scott testified before the Commerce and Environment Committees during their Joint Public Hearing in March, providing commentary on the practical implications of the regulatory overhaul and advocating for a feedback-driven implementation process. She was also a recent guest on an episode of the Connecticut Business and Industry Association’s (CBIA) Bizcast focused on “Understanding Release-Based Regulations.” Scott serves on the CBIA’s E2 Energy & Environmental Council Steering Committee and is immediate past chair of the Connecticut Bar Association Environmental Section. To view episodes of The Release Report and receive updates on the environmental, health & safety, and energy landscape content from Robinson+Cole, subscribe to the Environmental Law + blog.

The Release Report examines regulatory changes reshaping Connecticut’s environmental landscape
Robinson+Cole Environmental Partner Hosts New Video Podcast Series Sharing Insights on Connecticut’s Release-Based Cleanup Regulations teaser
June 11, 2014

Sikorsky Aircraft Corporation Recognizes Robinson+Cole for Sponsoring Home Run for Heroes

Home Run for Heroes Bluefish Baseball Game
April 30, 2014

ABA's Section of Litigation Recognizes Megan Baroni for Outstanding Contributions

American Bar Association's (ABA) Section of Litigation
September 10, 2025

Robinson+Cole Environmental Partner Hosts New Video Podcast Series Sharing Insights on Connecticut’s Release-Based Cleanup Regulations

Robinson+Cole’s Environmental Law + blog has launched a new video podcast series, The Release Report: Inside Connecticut’s Release-Based Cleanup Regulations. The series is hosted by Environmental partner Emilee Mooney Scott, a member of the Working Group convened under Public Act 20-09, which initiated the transition from the state's transaction-based Transfer Act to a Release-Based Cleanup Regulation (RBCR). Scott brings deep insight into the regulatory changes reshaping Connecticut’s environmental landscape. The Release-Based Cleanup Regulations, set to take effect on March 1, 2026, will replace the longstanding Transfer Act, which has governed environmental cleanup in the state for nearly four decades. Through The Release Report series, Scott will guide blog viewers and readers through the steps required under the new regulations—from discovery and reporting of releases to cleanup and closure—highlighting the implications for property transactions, redevelopment, and commercial and industrial operations across the state. “This video podcast series will explore how these new regulations will replace the longstanding Transfer Act,” said Scott. “I will provide valuable and in-depth insights on these new regulations, shedding light on the opportunities and challenges they present for stakeholders, so that they are well-prepared for the future of Connecticut's environmental landscape.” “The Release Report reflects Robinson+Cole’s commitment to providing timely, practical insights on the evolving regulatory landscape in Connecticut,” said James P. Ray, chair of the firm’s Environmental, Energy + Telecommunications group. “Emilee’s deep involvement in the development of the Release-Based Cleanup Regulations and her ability to translate complex policy into actionable guidance make this series an invaluable resource for our clients and the broader business and real estate community.” About the Host: Emilee Mooney Scott Emilee Mooney Scott is a recognized authority on Connecticut’s environmental regulations and a driving force behind the transition to a Release-Based Cleanup Framework. Scott was appointed to the Working Group jointly convened by the Connecticut Department of Energy and Environmental Protection and the Department of Economic and Community Development under Public Act 20-9 to advise on Connecticut’s release-based environmental investigation and remediation program. Scott testified before the Commerce and Environment Committees during their Joint Public Hearing in March, providing commentary on the practical implications of the regulatory overhaul and advocating for a feedback-driven implementation process. She was also a recent guest on an episode of the Connecticut Business and Industry Association’s (CBIA) Bizcast focused on “Understanding Release-Based Regulations.” Scott serves on the CBIA’s E2 Energy & Environmental Council Steering Committee and is immediate past chair of the Connecticut Bar Association Environmental Section. To view episodes of The Release Report and receive updates on the environmental, health & safety, and energy landscape content from Robinson+Cole, subscribe to the Environmental Law + blog.

The Release Report examines regulatory changes reshaping Connecticut’s environmental landscape
Robinson+Cole Environmental Partner Hosts New Video Podcast Series Sharing Insights on Connecticut’s Release-Based Cleanup Regulations teaser
June 11, 2014

Sikorsky Aircraft Corporation Recognizes Robinson+Cole for Sponsoring Home Run for Heroes

Home Run for Heroes Bluefish Baseball Game
April 30, 2014

ABA's Section of Litigation Recognizes Megan Baroni for Outstanding Contributions

American Bar Association's (ABA) Section of Litigation
November 12, 2013

Robinson & Cole Lawyers Promote Manufacturing Blog at SBANE's Prospectus 2013

 Manufacturing Law Blog
July 20, 2011

Attorneys Peter Knight and Ronald Zdrojeski Quoted in Connecticut Law Tribune

Connecticut Law Tribune
April 15, 2011

Megan Baroni Elected to Botanical Garden Board of Directors

February 27, 2007

Robinson & Cole Contributes $2500 to the Urban League of Greater Hartford

November 12, 2013

Robinson & Cole Lawyers Promote Manufacturing Blog at SBANE's Prospectus 2013

 Manufacturing Law Blog
July 20, 2011

Attorneys Peter Knight and Ronald Zdrojeski Quoted in Connecticut Law Tribune

Connecticut Law Tribune
April 15, 2011

Megan Baroni Elected to Botanical Garden Board of Directors

February 27, 2007

Robinson & Cole Contributes $2500 to the Urban League of Greater Hartford

Events

Past

Complying with Connecticut’s New UST Regulations: Key Points for Petroleum Marketers

Jun 10 2026
Connecticut Energy Marketers Association Webinar
Past

Legislative Issues Update

Jun 3 2026
CT Commercial Real Estate Conference
Past

Complying with Connecticut’s New UST Regulations: Key Points for Petroleum Marketers

Jun 10 2026
Connecticut Energy Marketers Association Webinar
Past

Legislative Issues Update

Jun 3 2026
CT Commercial Real Estate Conference
Past

The Release-Based Cleanup Regulations Are Live: What Now?

Jun 2 2026
Connecticut Legal Conference
Past

Underground Storage Tanks: Buried Hazards in Connecticut’s Revised UST Regulations

Feb 18 2026
Environmental Business Council of New England (EBC) Webinar
Past

Spill Response 101

Jan 22 2026
An EBC Connecticut Webinar
Past

Connecticut Released-Based Cleanup Regulations: Beginning to Consider the Possibilities

Nov 6 2025
An EBC Connecticut Webinar
Past

The Release-Based Cleanup Regulations Are Live: What Now?

Jun 2 2026
Connecticut Legal Conference
Past

Underground Storage Tanks: Buried Hazards in Connecticut’s Revised UST Regulations

Feb 18 2026
Environmental Business Council of New England (EBC) Webinar
Past

Spill Response 101

Jan 22 2026
An EBC Connecticut Webinar
Past

Connecticut Released-Based Cleanup Regulations: Beginning to Consider the Possibilities

Nov 6 2025
An EBC Connecticut Webinar

Environmental Law +

The Release Report #10: The RBCRs Are Here!

This is the tenth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.  At long last, the RBCRs are here! With a March 1, 2026, effective date, the RBCRs are now live. In this post, we will provide a brief refresher on what that means and share where things stand in in the first week of March as the regulations are just taking effect. Where Things Stand As of March 1, the law has changed in several important ways, including: New transfers of businesses and real property no longer trigger the Transfer Act.  Transfers of businesses and real property after March 1, 2026, no longer trigger the Transfer Act. That said, Transfer Act “certifying parties” that have not yet finished their work will be required to finish site-wide investigation and remediation under the Transfer Act. An information sheet available on DEEP’s website provides additional detail on the interplay of the Transfer Act and RBCRs. Identification of contamination can lead to the “discovery” of a pre-existing release, and trigger obligations to investigate and remediate it.  As we discussed an earlier post, the “discovery” of a pre-existing release can occur through environmental sampling or the observation of “multiple lines of evidence” that a release has occurred. DEEP has now provided a guidance document explaining when a release can be discovered through multiple lines of evidence. New releases are still reported under the March 2022 spill reporting regulations, and response can sometimes be managed by Permitted Environmental Professionals (PEPs).  As discussed in a prior post regulations were promulgated in March of 2022 (R.C.S.A. § 22a-450-1 et seq.) that require reporting of certain new releases. Those regulations remain in effect.  Now, after such releases are reported, certain immediate actions are required (as discussed previously) and some of those response actions can be managed by PEPs. What’s New In the last few weeks DEEP has provided a number of training sessions on various aspects of the RBCRs.  Information on training sessions, and an opportunity to sign up, are available on DEEP’s website.  DEEP has also recently released its long-awaited Release, Environmental Assessment and Cleanup Tracker or REACT database.  The REACT database provides a wealth of information on remediation sites statewide, and it will become more detailed over time as it is populated with new submittals under the RBCRs and other programs.  What Happens Next In the coming weeks, we expect DEEP to continue to release additional guidance and other information on the RBCRs. The working group convened under Public Act 20-09 had its last meeting on February 26, but a new working group will be convened soon to advise DEEP on the implementation of the RBCRs.  As the RBCRs are implemented, please stay tuned to the Environmental Law + blog as we continue to share updates and insight.

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Federal Courts Unswayed by Administration Stop Work Orders

Echoing recent rulings from the District Court for the District of Columbia, on January 16, 2026, the District Court for the Eastern District of Virginia granted Dominion Energy’s request for a preliminary injunction, lifting the Trump administration’s suspension of the Coastal Virginia Offshore Wind project. Earlier that same week, two other judges in same district  granted similar requests made by Equinor for its Empire Wind project and Ørsted for its Revolution Wind project. Work on the three projects has resumed and, in the case of Revolution Wind, construction is nearing completion. The three developers successfully argued that the work stoppages would result in imminent and irreparable harm. Justice Department officials countered by claiming that the national security concerns that putatively justified the December 2025 stop work orders outweighed the developers’ economic interests. Thus far, reviewing courts have held that those security concerns, which allege a generalized risk of interference with radar systems, have not been sufficiently articulated.  While the preliminary injunctions allow the projects to continue, the cases will continue to be litigated on their merits. Concerning the remaining two projects subject to the stop work order, Vineyard Wind is challenging the stop work order in Massachusetts federal court and Sunrise Wind filed for an injunction in the District of Columbia. 

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Offshore Developers Wind Up Challenges To Latest Stop Work Orders

In response to the Trump administration’s latest suspension of offshore wind development, three of the five affected developers have filed lawsuits in federal court seeking to overturn the stop work orders: Dominion Energy on behalf of its Coastal Virginia Offshore Wind project; Ørsted on behalf of its Revolution Wind project; and Equinor on behalf of its Empire Wind project. All three projects are under construction, with Revolution Wind nearly 90% complete and Empire Wind over 60% complete. Consistent with prior legal actions opposing the administration’s efforts to halt offshore wind development, the complaints allege that the Department of the Interior’s (DOI) order of December 22, 2025 (which the plaintiffs claim is costing them millions of dollars for each day the projects are on hold), is illegal and that the DOI’s alleged national security justification for the orders is baseless and pretextual. The developers are backed by the Attorneys General of Connecticut and Rhode Island, who filed their own actions to block the shutdowns. Those cases are now consolidated in the U.S. District Court for the District of Columbia. To date, federal courts have been receptive to arguments raised by both developers and the states that are relying on offshore generation. Ørsted successfully brought suit in the District of Columbia challenging the DOI’s prior efforts to block Revolution Wind, and on December 8, 2025, a federal court in Massachusetts ruled that the administration’s blanket ban on permit application review of wind projects was illegal. Ørsted’s prior action in the District of Columbia was heard by Judge Royce Lamberth, who will preside over the newly consolidated cases.  An initial hearing is scheduled for Monday, January 12, 2026.

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The Release Report #9: Closure Documentation and DEEP Review

This is the ninth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.  The final task in the remediation process is documenting that remediation is complete, and no further action is required. This post discusses the documentation requirements under the RBCRs, and how they differ from documentation requirements under the Transfer Act. Verification Under the Transfer Act First, a review of current procedures under the Connecticut Transfer Act will set the stage. The Transfer Act requires a site-wide investigation and remediation effort. Through this process, all “areas of concern” where a release occurred or may have occurred are investigated and, if needed, remediated. When that is done, a Licensed Environmental Professional, or LEP, prepares a document called a Verification. Typically, the Verification attests that the entire parcel has been investigated in accordance with prevailing standards and guidelines, and that the establishment has been remediated in accordance with the remediation standards. When work is complete at a specific geographic portion of the site (but remains underway at other portions) an LEP can prepare a Verification for just the completed portion of the site and save the remainder of the site for later Verifications. Ultimately, efforts at all portions of the Transfer Act establishment parcel must be closed through Verification reports. After the Verification is submitted, the Connecticut Department of Energy and Environmental Protection (DEEP) may initiate an audit of the Verification within one year after it is submitted. If there is no audit, or if DEEP is satisfied after the audit, then the Verification stands and the Transfer Act process is complete.  Release Remediation Closure Reports In contrast to the Transfer Act, the RBCRs do not require a site-wide effort. Instead, the RBCRs require that releases be investigated and remediated as they are discovered (see our prior post on Discovery of an Existing Release). Consequently, documentation will be developed and submitted on a release-by-release basis.  Under the RBCRs, documentation that a release has been remediated to the extent required will be provided in a “release remediation closure report.” The RBCRs provide a list of the information the release remediation closure report must include, and further detail is provided in the companion blog post. Release remediation closure reports may be prepared by either a LEP or, for less-impactful releases, a Permitted Environmental Professional or PEP. We discussed PEPs in a prior blog post on Immediate Actions. Release remediation closure reports, and other records (like the tier checklist form discussed in a prior post on Oversight Tiers), will be subject to audit by DEEP, as Verifications are now. The audit process will look a little different under the RBCRs, however. Under the Transfer Act, DEEP audits the final Verification report submitted at the end of the remediation process. DEEP does not audit interim documents like Completion of Investigation reports, although the audit of the final Verification may bring to light issues with those interim documents. By contrast, under the RBCRs, DEEP can audit the release remediation closure report and any other reports required to be signed off by an LEP or certified by a PEP. In other words, interim documents like tier checklists can be audited. In another change from the Transfer Act, the RBCRs set forth different levels of DEEP review and audit. A screening audit is an administrative review by DEEP performed within 180 days after a release record (like a release remediation closure report, tier checklist, or other document) is submitted. This screening audit may commence and be conducted without notice to the LEP, PEP, or other responsible party.  DEEP may reject a release record after a screening audit and notify the LEP, PEP, or other responsible party that a new release record is required. A focused audit is the review of a single release record and may address the entire record or focus on specific areas.  These may be selected at random or identified through screening audits. Notice is provided, which must include identification of additional information necessary for DEEP to determine compliance. A focused audit may result in acceptance of the release record, the order for a more detailed full audit, or outright rejection of the release record. A full audit is a review of several or all of the release records associated with a release. This also involves notice and identification of additional information needed. Such a full audit can result in DEEP rejecting one or more of the release records and requiring resubmission. Transfer Act Sites After March 1, 2026 For sites that are enrolled in the Transfer Act before March 1, 2026, the site-wide investigation and remediation process discussed above will still be required after March 1. As noted above, Transfer Act Verifications typically apply to the entire parcel, but Verifications may be filed for a portion of the parcel if that portion has been fully investigated and remediated. A statutory change in the 2025 legislative session broadens this “portion verification” concept to permit remediation of a Transfer Act site to be documented in a release-by-release manner. Public Act 25-54 provides that any Certifying Party (i.e., the person responsible for completing work on a Transfer Act site) may complete site-wide investigation as required under the Transfer Act and submit to DEEP a report that catalogues each release identified by such site-wide investigation. Once all releases at a site have been catalogued, they can be closed one by one through submission of release remediation closure reports. After all releases have been closed, the Certifying Party may then request from DEEP a letter confirming that all releases have been closed and that Transfer Act work is complete. While this pathway may not be of interest to all Certifying Parties, it might be useful at sites with multiple Certifying Parties who want to more clearly define which party is working on which release areas.

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Just When You Thought It Was Safe To Go Back Into The Water – Trump Administration Halts Offshore Wind Projects

On December 22, citing security concerns, the U.S. Department of the Interior (DOI) announced that it was pausing leases for all offshore wind projects currently under construction. The stop-work order blocks further construction of Vineyard Wind 1, Revolution Wind, Coastal Virginia Offshore Wind, Sunrise Wind, and Empire Wind 1. All five projects had obtained leases during the Biden administration. Vineyard Wind 1 is already partially operational, with nearly half of the project’s 62 turbines generating electricity. Both Empire Wind and Revolution Wind were the subject of prior stop-work orders, but following negotiations with the Trump administration in the case of Empire Wind and litigation in the case of Revolution Wind, both projects had resumed construction. Currently, only two small wind farms in U.S. coastal waters are fully operational – Block Island Wind off the coast of Rhode Island with five turbines and South Fork Wind off the coast of New York with twelve turbines. In announcing the work stoppage, Secretary of the Interior Doug Burgum claimed that “recently completed classified reports” by the Department of Defense (DOD) identified possible radar interference as a potential security risk. Project proponents have noted that the project permitting process included review and approval by the DOD. This latest stop work order will likely be challenged. Earlier this month, a federal court in Massachusetts ruled that the administration’s ban on the review of offshore wind permits, a policy announced when President Trump took office, was illegal. There, the court determined that in the absence of a clearly articulated rationale beyond the President’s personal contempt for wind turbines, the offshore ban was arbitrary and capricious and a violation of the Administrative Procedures Act (APA). While the DOI’s new stop work order cites emerging national security concerns, a federal court may ultimately need to determine whether it, too, violates the APA. In the meantime, approximately $25 billion worth of projects and an estimated 10,000 jobs face an uncertain future.

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The Release Report #8: Remediation Standards and Regulations

This is the eighth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.  As remediation projects are planned and performed, the big question is: “How clean is clean enough?” This post discusses remediation standards under the RBCRs, and how those standards will change from the standards in use today. Sites being remediated under the Transfer Act must achieve compliance with the Remediation Standard Regulations or RSRs set forth at R.C.S.A. § 22a-133k-1 et seq. The RSRs set forth the concentrations of various substances that are permitted to be present in soil and groundwater.  These standards vary depending on context. For example, at a site that is limited to industrial or commercial use, soil contamination is permitted at higher levels than would be the case for a site that might be in residential use. This is because soil standards are set based on exposure assumptions, and a child playing in the yard would have greater exposure to soil than an adult at work. Similarly, when a site has groundwater that is used or may be used as drinking water, the standards are more stringent than when the groundwater has already been deemed not suitable for drinking. The RSRs also provide a number of pathways to compliance that serve as alternatives to achieving the numerical standards set forth in the regulations. For example, soil that is contaminated above the numerical criteria is permitted to remain in place, subject to a restriction recorded on the land records called an environmental use restriction (or EUR), when it is under a building and therefore protected from human exposure and movement caused by rain. These familiar features of the RSRs will remain in place after March 1, 2026. In fact, substantially all of the text of the RSRs will be moved from where it currently resides in R.C.S.A. § 22a-133k-1 et seq. to the new RBCRs at R.C.S.A. § 22a-133tt-1 et seq. The existing RSR sections will be replaced with a cross-reference to the new location in the RBCRs where substantially the same text will reside.  In other words, sites being remediated under the Transfer Act, and releases being remediated under the RBCRs, will be working toward the same set of standards. Changes to Remediation Standards and Approaches There are a few changes being made to the remediation standards as we transition from the RSRs to the RBCRs. In addition to the familiar residential and commercial/industrial categories, the RBCRs provide numerical soil standards for two new land use categories: Managed Multifamily: The managed multifamily criteria will be available for parcels with 4 or more dwelling units, provided such dwelling units are managed by an association or a professional property management company. The idea is that such a professional management company can provide rules (like no vegetable gardening for example), intended to keep people safe from residual soil contamination. Passive Recreation: The passive recreation criteria apply to sites subject to an environmental use restriction or conservation easement prohibiting any residential use except passive recreation. Currently, recreation is considered to be a residential activity. Therefore, a property traversed by a bike trail would not be eligible for industrial/commercial standards, because the bike trail would be said to constitute a residential use. Passive recreation is recreation that uses trails or roads for activities such as running, hiking, biking, and horseback riding. Use of specific areas for a sustained period of time, like sports fields and beaches, are not considered passive recreation. Once again, the idea is that these sorts of low-touch activities are less risky than true residential use of property.  The RBCRs also provide a streamlined process for allowing certain impacted soil to remain in place if it is inaccessible under a building, or a concrete or asphalt surface. If specified criteria are met, such soil can remain in place provided the property owner maintains the covering in good condition, regularly inspects it, provides reports on its maintenance, and properly manages soil that might be exposed during a maintenance activity. An affidavit explaining the situation must be recorded on the land records, but this is expected to be a simpler process than the process required to secure an environmental use restriction. A similar streamlined pathway is available to allow on-site management of historically impacted material, i.e., soil that has been historically intermixed with coal ash, wood ash, coal fragments, coal slag, coal clinkers, or asphalt paving fragments. With that context, we can clear up a common source of confusion. Many have wondered if the RBCRs are applicable to Transfer Act sites. While certain provisions of the RBCRs are not applicable to Transfer Act sites (like reporting and tiering), the remediation standards of the RBCRs, including the new provisions, are applicable to Transfer Act sites. In our next posts, we will discuss closure documentation.

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EPA Issues “Compliance First” Memo: Key Takeaways for Regulated Entities

On December 5, 2025, Craig J. Pritzlaff, Acting Assistant Administrator of the EPA’s Office of Enforcement and Compliance Assurance (OECA), issued an internal memorandum instituting a “Compliance First” approach, immediately effective for all civil enforcement and compliance activities. This memo claims to introduce a policy shift: prioritizing timely and effective compliance over punitive enforcement and expansive regulatory interpretations. EPA’s goal is clear, swift, and efficient compliance, achieved by the “clearest, most defensible interpretations of our statutory and regulatory mandates.” Key Elements of the “Compliance First” Policy Compliance Assistance ToolkitEnforcement is not the only tool. Proactive outreach, technical assistance, voluntary audits, and self-reporting are highlighted as means to encourage regulated entities to “find and fix” issues before enforcement becomes necessary. State and Tribal CoordinationThe EPA is committed to deferential, collaborative engagement with authorized states and tribes. Civil enforcement activities will avoid duplication and promote consistency by coordinating closely with local agencies, providing them with technical support, and ensuring states lead where they have primary jurisdiction. Transparent Communication and “No Surprises”Open, transparent dialogue is mandated throughout inspections and enforcement. The EPA pledges a “no surprises” approach and wants regulated entities to proactively identify and address potential compliance issues, building trust, and avoiding unexpected enforcement escalation. Clarity and Legal Precision in FindingsFindings of violation must be “clear and unambiguous” and based on the “best reading” of statutes and regulations. Expansive or creative interpretations that create uncertainty or deviate from precedent are expressly rejected, especially in light of recent Supreme Court decisions. Material legal ambiguities must be elevated to national EPA leadership for resolution, ensuring consistent application across regions. Timely and Efficient ComplianceEPA staff are directed to focus on rapid resolution of violations, with compliance – not punishment – as the North Star. Prolonged or punitive strategies are deemphasized to avoid delaying environmental protection and economic operations. Formal enforcement and injunctive relief (such as administrative or judicial action) will be used only when informal or compliance assistance measures are insufficient or in emergencies. Remedies must be narrowly tailored, directly tied to specific violations, and based on clear legal requirements. EPA’s April 26, 2021 memorandum (Using All Appropriate Injunctive Relief Tools in Civil Enforcement Settlements), which focused on expansive injunctive measures and supplemental environmental projects (SEPs), is also rescinded, pending new guidance. OECA Assistant Administrator approval is required for non-standard remedies like third-party audits. Reasoned, Transparent Decisions Using LEAPSThe memo introduces the LEAPS framework for enforcement decisions: Law: Use the clearest statutory/regulatory interpretation; Evidence: Rely on solid, unequivocal facts; Analysis: Apply logic and connect facts with law; Programmatic Impact: Consider effects on EPA programs; and Stakeholder Impact: Assess how actions affect states, tribes, and regulated entities The memo states that EPA is aiming for transparent, reasoned decisions anchored in LEAPS to make enforcement predictable and defensible. Practical Implications for the Regulated Community Potential for more opportunities for rapid, voluntary compliance and proactive technical assistance. Legal disputes over novel or ambiguous regulatory interpretations should be elevated to national leadership, potentially providing regulated entities with a new escalation pathway. Formal remedies such as SEPs and wide-ranging monitoring should be restricted, and enforcement actions should now be both more predictable and tied tightly to statutory requirements. EPA will soon issue a single guidance document to harmonize enforcement practices agency-wide, offering more clarity and consistency for regulated parties. Final Thoughts While this “new” policy shares similarities with prior EPA enforcement guidance and does not create legally binding rights, the intent appears to portray a shift in EPA enforcement philosophy to prioritizing clarity, efficiency, and cooperation over adversarial posturing or creative statutory interpretations. While it is too early to know what practical implications this will have for enforcement actions, EPA’s memo is a helpful reminder for regulated entities to review their compliance programs, prepare for inspections, and document legal positions carefully to align with the “best reading” standard now embedded in EPA practice.

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Court Knocks the Wind out of Trump Administration’s Offshore Ban

On December 8, 2025, a Massachusetts federal court ruled that the Trump administration’s ban on permit application review for offshore and onshore wind projects was illegal.  While the ruling will not necessarily result in the issuance of new permits, it lifts the moratorium on review and processing of applications. In May 2025, a coalition of 17 states, the District of Columbia, and the Alliance for Clean Energy filed suit in federal court to overturn an executive order announced in the early days of the administration that placed all federal permitting of wind projects on hold. In granting plaintiffs’ motion for summary judgment, Judge Patti Saris agreed that the executive order was arbitrary and capricious, in violation of the Administrative Procedures Act (APA).  The administration had argued both that the executive order was a lawful action within the President’s authority to set energy policy and the plaintiffs lacked standing to sue. The court was not persuaded.  Defendants overcame the administration’s standing challenge by providing adequate evidence of ongoing or imminent injuries due to the moratorium, including project delays and the states’ inability to reduce greenhouse gas emissions. With a “scant” administrative record to review, Judge Saris then determined that because “the sole factor the defendants considered in deciding to stop issuing permits was the president’s direction to do so,” the Government had not reasonably considered all relevant issues or reasonably explained its decision, as required by the APA. The administration may appeal the decision. Even if the ruling withstands a challenge, it will not result in fast tracking or green-lighting new permit applications. While the administration can no longer decline to consider wind projects pursuant to the executive order, nothing compels federal agencies to approve them.

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The Release Report #7: Oversight Tiers

This is the seventh in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.  Under the Transfer Act, the majority of site remediation efforts are led by licensed environmental professionals (LEPs).  For a minority of sites with especially serious contamination, remediation efforts are subject to direct oversight by the Department of Energy and Environmental Protection (DEEP).  This same basic framework continues under the RBCRs, with the majority of release remediation efforts led by LEPs. This post discusses how different releases are assigned to different “tiers” of oversight, and the impact of such tier assignment. Some releases discovered and addressed under the RBCRs will be resolved in less than one year. For certain new releases and especially serious existing releases (called “significant existing releases” in the RBCRs) immediate actions are required as discussed in a prior post, and these immediate actions may be enough to completely resolve the release. Other releases will be closed within a year, even if not required, thanks to a straightforward remedial approach.  If a release has not been closed within one year after occurrence or discovery, the RBCRs provide that it must be assigned to an oversight “tier” based on the risks posed by the release. This applies to both existing releases and new releases. As discussed below, the tier to which a release is assigned controls the oversight, deadlines, and fees associated with a release. Tiers In order to assign a release to a tier, an LEP must complete the Tier Checklist Form provided in the appendix to the RBCRs. This Tier Checklist Form must be completed within one year after the occurrence or discovery of the release. Tiers are assigned as follows: Tier 1A: Releases that pose the highest risk and/or are poorly understood. If tier characterization (discussed in the last post) has not been completed, or if required immediate actions have not been completed, then the release is assigned to Tier 1A. Releases are also assigned to Tier 1A if receptors are not known and documented through completion of a scoping level ecological risk assessment, a drinking water receptor survey, and a vapor intrusion survey. Tier 1B: Releases that are better understood than Tier 1A but still higher risk than other releases. These include releases that involve a groundwater plume migrating off the source parcel, releases for which a vapor intrusion pathway is present, and releases for which a drinking water receptor pathway is present. Even if none of the above conditions is true, a release is categorized as Tier 1B until a remedial action plan has been prepared. Tier 2: Releases that pose a lower degree of risk than Tiers 1A and 1B but for which additional remediation is required. For example, Tier 2 releases are those that do not fall within Tiers 1A and 1B but still require soil remediation or the elimination of exposure pathways. Tier 3: Releases for which groundwater is being addressed through monitored natural attenuation and no additional active work is required. Impact of Tier Assignment Releases assigned to Tiers 1B through 3 will be managed by an LEP much the way the majority of Transfer Act remediation projects are managed now. Tier 1A releases will be subject to direct oversight by DEEP, like a relatively small proportion of Transfer Act sites today require DEEP to approve the remediation. Different tiers of releases are subject to differing fees.   Initial fee (due on tier assignment) Annual fee (due one year after tier assignment and annually thereafter) Tier 1A $3000 $3000 + ($300 x number of years since tier assignment) Tier 1B $1500 $1500 + ($150 x number of years since tier assignment) Tier 2 $1000 $1000 + ($100 x number of years since tier assignment) Tier 3 $500 $50 + ($5 x number of years since tier assignment) As set forth in the RBCRs, the annual fee increases by 10% of the base fee amount for every year that has passed since initial tier assignment (i.e., when the Tier Checklist Form is submitted for the first time). In other words, a Tier 3 release would be subject to an annual fee of $70 four years after tier assignment. Different tiers are also subject to different deadlines: Tier 1A: Within one year after initial tier assignment, Tier 1A releases must either be closed or assigned to a lower-risk tier (i.e., Tiers 1B, 2 or 3). Tier 1B: Within two years after initial tier assignment, Tier 1B releases must either be closed or assigned to a lower-risk tier. Tier 2: Within four years after initial tier assignment, Tier 2 releases must either be closed or assigned to Tier 3. Tier 3: Must be closed within five years after initial tier assignment. The RBCRs provide that single one-year extensions may be requested for releases in Tiers 1A, 1B and 2. For Tier 3 releases, five-year extensions may be requested and approved as long as the groundwater plume remains in a diminishing state that is naturally attenuating consistent with the conceptual site model. In our next posts, we will discuss remediation standards and closure documentation.

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Connecticut DEEP Reissues Stormwater and Pretreatment General Permits

The Connecticut Department of Energy and Environmental Protection (DEEP) has been busy reissuing its suite of general permits (GPs) for wastewater and stormwater discharges. In October, DEEP reissued the Commercial Stormwater General Permit, Industrial Stormwater General Permit, and Pretreatment General Permits for Significant Industrial Users and Non-Significant Industrial Users. Below are highlights of significant changes to each reissued GP, as well as important compliance deadlines and considerations for regulated entities. 1. The Commercial Stormwater General Permit (CSGP) covers commercial sites with 5 or more acres of contiguous impervious surface, including shopping centers, business parks, schools, retail complexes, car dealerships, and financial and health services with large campuses. The reissued CSGP includes the following notable changes: Expanded Industry Coverage: The new CSGP uses an updated definition of “Commercial Activities” referencing Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS) codes and capturing a broader range of commercial activities than the previous permit. Businesses should review Appendix A of the CSGP to determine if their SIC/NAICS code is listed. New Registration Requirements: Online registration through a yet-to-be-announced platform; $625 fee. Stormwater Management Plan: Required for all registrants, with expanded control measures and annual analytical plus quarterly visual monitoring. Other Updates: Updated control measure requirements including new measures on deicing practices, spill prevention and cleanup, and lawn and garden center Best Management Practices. New quarterly visual monitoring and annual analytical monitoring of 19 parameters to better assess water quality impacts. Deadlines: Registration opens December 1, 2025. Existing permittees must register by April 1, 2026. Existing sites without permit coverage (not previously registered) must register by December 1, 2026. New sites must apply at least 60 days before beginning discharge. Potential Compliance Traps: Many facilities not previously regulated (e.g., large retail, educational campuses) may now be required to register. Failure to review the new SIC/NAICS applicability could result in unintentional noncompliance. 2. The Industrial Stormwater General Permit(IGP) covers industrial facilities, as defined by SIC/NAICS codes in Appendix A to the IGP, that discharge stormwater to waters of the state. Industrial facilities should check their SIC/NAICS code against Appendix A to the IGP. The reissued IGP includes the following notable changes: Alignment with EPA’s 2021 MSGP: Incorporates new “Resilience Measure” requirements in the Stormwater Pollution Prevention Plan (SWPPP) tracking the federal government’s Multi Sector General Permit. Corrective Actions Framework: New requirements for documenting and implementing corrective actions. Annual Reports: Now required each April for the prior calendar year. Electronic Reporting: Discharge Monitoring Reports (DMRs) must be submitted via NetDMR; online noncompliance reporting is now mandatory. Registration Fees: $1,250 for larger companies; $625 for smaller companies, federal, state and municipal-operated industrial activities Signage: Facilities must post a sign indicating permit coverage. Deadlines: Registration opens November 1, 2025. Existing permittees must register by April 1, 2026. New sites must register at least 90 days before discharge. Potential Compliance Traps: If stormwater contacts industrial materials, activities, or operations, it is likely that the facility needs coverage. If all industrial facilities are fully sheltered and qualify under related DEEP rules, such facilities may qualify for a No Exposure Certification. In addition, the expanded monitoring, reporting, and corrective action requirements are more rigorous. Facilities must update SWPPPs and ensure timely electronic submissions to avoid enforcement. 3. DEEP also reissued two Pretreatment General Permits for Significant Industrial Users (SIU GP) and Non-Significant Industrial Users (Non-SIU GP). The SIU GP covers indirect discharges from significant industrial users (SIUs), including metal finishing, process, and non-process wastewaters, as well as dewatering and remediation wastewaters to sanitary sewers. The Non-SIU GP covers non-significant industrial users (Non-SIUs) not subject to federal categorical standards. DEEP issued a Pretreatment Permit Decision Chart to aid entities in determining which pretreatment permit may be applicable. The reissued Pretreatment GPs include the following notable changes: Updated Definitions: Flow thresholds now based on average monthly flow (≥25,000 gpd of all process wastewater for SIUs). Expanded Coverage: Dewatering and remediation discharges to Publicly Owned Treatment Works (POTWs) are now included in the SIU GP. Application Fees: For SIU GP, between $1,000 and $6,250 depending on the discharge type. For the Non-SIU GP, there is no DEEP fee but the POTWs reserve the right to collect fees associated with initial submission of a Notification Form. Effluent Limits: New limits for mercury, PFAS, pH, temperature, and PCBs. Facilities may need to invest in new treatment or monitoring technologies to meet these limits. Streamlined Process: Certification of No Change is a registration option for existing permittees; Non-SIU GP registration is notification-only. Deadlines: Registration opens December 1, 2025. Existing SIUs and Non-SIUs must register by March 1, 2026. New SIUs must register at least 180 days prior to discharge. New Non-SIUs must submit a Notification Form at least 60 days prior to discharge. Potential Compliance Trap: The removal of Qualified Professional Engineer (QPE) and Natural Diversity Data Base (NDDB) certification requirements is intended to streamline the process, but new effluent limits (especially for PFAS and mercury) may require operational changes. Important Considerations and Practical Tips The reissued GPs bring significant changes and expanded coverage to stormwater and pretreatment permit requirements. Regulated entities should carefully review the reissued GPs to determine if their activities are subject to permitting registration and compliance requirements, including electronic registration, updated reporting requirements, application fees, and expanded monitoring, BMPs, and corrective action requirements. Facilities should review and update their plans (e.g., SWPPP, SMP, SPCP) and train staff accordingly. Existing permittees must pay close attention to registration deadlines to maintain interim coverage. DEEP has also made it abundantly clear that, in an effort to increase permit processing timelines, incomplete applications will be rejected and a new application, with a new fee, will need to be submitted. DEEP has shared that the most common reasons for incomplete applications in the past were missing or improperly signed Registrant Certification and missing or incomplete sampling data. Robinson+Cole’s Environmental group will continue to monitor developments and provide updates concerning DEEP’s general permit and other discharge permitting requirements for stormwater and wastewaters.

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Firm Highlights

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Julianna Charpentier Recognized as an “Up & Coming Lawyer”
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Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

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Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

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Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
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Robinson+Cole Expands National Platform with Four Lateral Partners

Robinson+Cole announced the addition of four lateral partners—J. Zachary Balasko, Eric Del Pozo, Brya M. Keilson and Victor R. Salgado, accelerating the firm’s continued investment in the growth of its national bankruptcy and business litigation capabilities. Balasko and Keilson join the firm’s Bankruptcy + Reorganizations group in Washington, DC, and Wilmington, DE, respectively, while Del Pozo and Salgado join the Business Litigation group in Hartford, CT, and Washington, DC. These strategic hires enhance the firm’s ability to serve clients navigating complex, high‑stakes bankruptcy, restructuring, government enforcement, and related litigation matters nationwide and expand the firm’s depth and reach across key markets. “These additions meaningfully reinforce the depth and versatility of our business litigation and restructuring platform and reflect a deliberate approach to strengthening these areas in ways that directly benefit our clients,” said J. Michael Wirvin, the firm’s Managing Partner. “Eric, Zak, Brya, and Victor each bring sophisticated experience and sound judgment that enhance our ability to advise clients through some of their most critical and challenging matters. Their arrival reflects our continued focus on building cohesive, multi-disciplinary teams with capabilities that extend across multiple markets.” J. Zachary Balasko joins the firm as a Bankruptcy + Reorganizations partner based in Washington, DC. His practice focuses on complex Chapter 11 cases and bankruptcy‑related litigation across the country, representing debtors, secured creditors, creditors’ committees, and governmental entities. Balasko brings substantial experience from both private practice and prior service with the U.S. Department of Justice, where he handled major insolvency matters involving federal interests. Eric Del Pozo joins Robinson+Cole’s Hartford, CT office as a Business Litigation partner focusing on complex commercial litigation and appellate matters, representing businesses and public entities in regulated industries in high-stakes and sophisticated disputes. Del Pozo brings experience from senior roles in government and private practice, where he has represented clients at both the trial and appellate levels. Brya Keilson joins Robinson+Cole as a Bankruptcy + Reorganizations partner in the firm’s Wilmington, DE office, one of the nation’s leading venues for complex bankruptcy proceeding . She represents debtors, creditors, committees, trustees, and other parties in interest in sophisticated Chapter 11 and Chapter 7 cases. Keilson is widely experienced in contested bankruptcy matters and frequently advises clients on both strategic and practical considerations throughout the restructuring process. Victor Salgado joins Robinson+Cole as a Business Litigation partner in the firm’s Washington, DC office. He brings significant experience from both government and private practice, including eight years as a federal prosecutor with the U.S. Department of Justice in Washington, DC, where he handled high‑profile and complex cases focusing on public corruption as well as crimes involving financial institutions. Salgado will also work closely with the firm’s Bankruptcy + Reorganizations group on contested matters arising in complex restructurings and related litigation. In addition, Destiney Parker-Thompson joins the firm as a Bankruptcy + Reorganizations associate in the Wilmington office. Parker‑Thompson focuses her practice on bankruptcy, restructuring, and related litigation matters, drawing on experience representing debtors, creditors, and financial institutions in complex Chapter 11 cases. She previously served as a judicial law clerk to the U.S. Bankruptcy Court for the District of Delaware and the U.S. Court of Appeals for the Third Circuit, bringing valuable insight to sophisticated restructuring matters. Robinson+Cole’s Bankruptcy + Reorganizations group has recently been recognized for its role in several of the most complex and precedent‑setting restructuring matters in the country, earning multiple national honors for its work in high‑profile Chapter 11 cases and related litigation. The group has guided stakeholders through landmark proceedings—including award‑recognized reorganizations, a first‑of‑its‑kind bankruptcy confirmed with a Section 524(g) injunction, and other transformative restructurings—reflecting the team’s ability to deliver strategic, results‑driven counsel in matters with significant legal and financial implications.

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Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

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Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

News
Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.

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Robinson+Cole’s People-First Culture Recognized in Vault’s 2027 Rankings
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Robinson+Cole Expands National Platform with Four Lateral Partners

Robinson+Cole announced the addition of four lateral partners—J. Zachary Balasko, Eric Del Pozo, Brya M. Keilson and Victor R. Salgado, accelerating the firm’s continued investment in the growth of its national bankruptcy and business litigation capabilities. Balasko and Keilson join the firm’s Bankruptcy + Reorganizations group in Washington, DC, and Wilmington, DE, respectively, while Del Pozo and Salgado join the Business Litigation group in Hartford, CT, and Washington, DC. These strategic hires enhance the firm’s ability to serve clients navigating complex, high‑stakes bankruptcy, restructuring, government enforcement, and related litigation matters nationwide and expand the firm’s depth and reach across key markets. “These additions meaningfully reinforce the depth and versatility of our business litigation and restructuring platform and reflect a deliberate approach to strengthening these areas in ways that directly benefit our clients,” said J. Michael Wirvin, the firm’s Managing Partner. “Eric, Zak, Brya, and Victor each bring sophisticated experience and sound judgment that enhance our ability to advise clients through some of their most critical and challenging matters. Their arrival reflects our continued focus on building cohesive, multi-disciplinary teams with capabilities that extend across multiple markets.” J. Zachary Balasko joins the firm as a Bankruptcy + Reorganizations partner based in Washington, DC. His practice focuses on complex Chapter 11 cases and bankruptcy‑related litigation across the country, representing debtors, secured creditors, creditors’ committees, and governmental entities. Balasko brings substantial experience from both private practice and prior service with the U.S. Department of Justice, where he handled major insolvency matters involving federal interests. Eric Del Pozo joins Robinson+Cole’s Hartford, CT office as a Business Litigation partner focusing on complex commercial litigation and appellate matters, representing businesses and public entities in regulated industries in high-stakes and sophisticated disputes. Del Pozo brings experience from senior roles in government and private practice, where he has represented clients at both the trial and appellate levels. Brya Keilson joins Robinson+Cole as a Bankruptcy + Reorganizations partner in the firm’s Wilmington, DE office, one of the nation’s leading venues for complex bankruptcy proceeding . She represents debtors, creditors, committees, trustees, and other parties in interest in sophisticated Chapter 11 and Chapter 7 cases. Keilson is widely experienced in contested bankruptcy matters and frequently advises clients on both strategic and practical considerations throughout the restructuring process. Victor Salgado joins Robinson+Cole as a Business Litigation partner in the firm’s Washington, DC office. He brings significant experience from both government and private practice, including eight years as a federal prosecutor with the U.S. Department of Justice in Washington, DC, where he handled high‑profile and complex cases focusing on public corruption as well as crimes involving financial institutions. Salgado will also work closely with the firm’s Bankruptcy + Reorganizations group on contested matters arising in complex restructurings and related litigation. In addition, Destiney Parker-Thompson joins the firm as a Bankruptcy + Reorganizations associate in the Wilmington office. Parker‑Thompson focuses her practice on bankruptcy, restructuring, and related litigation matters, drawing on experience representing debtors, creditors, and financial institutions in complex Chapter 11 cases. She previously served as a judicial law clerk to the U.S. Bankruptcy Court for the District of Delaware and the U.S. Court of Appeals for the Third Circuit, bringing valuable insight to sophisticated restructuring matters. Robinson+Cole’s Bankruptcy + Reorganizations group has recently been recognized for its role in several of the most complex and precedent‑setting restructuring matters in the country, earning multiple national honors for its work in high‑profile Chapter 11 cases and related litigation. The group has guided stakeholders through landmark proceedings—including award‑recognized reorganizations, a first‑of‑its‑kind bankruptcy confirmed with a Section 524(g) injunction, and other transformative restructurings—reflecting the team’s ability to deliver strategic, results‑driven counsel in matters with significant legal and financial implications.

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Robinson+Cole Integrates Thomson Reuters’ Deep Research into Newcode.ai Platform to Advance Secure, Verifiable Legal Research

Robinson+Cole has expanded its firmwide artificial intelligence (AI) capabilities by integrating Thomson Reuters’ Deep Research directly into Newcode.ai, the agentic AI platform implemented last year by the firm to support legal workflows across practices. With this integration, Robinson+Cole is one of only two law firms with direct access to the Deep Research API—and the only firm deploying it through Newcode.ai. Building on its 2025 partnership with Newcode.ai —making Robinson+Cole the first Am Law 200 firm to adopt the platform—the firm has continued to expand its AI capabilities as part of a broader strategy focused on secure deployment, ethical use, and seamless integration into daily legal work. The integration enables Robinson+Cole attorneys to conduct complex, multi‑step legal research and receive verifiable, citation‑backed responses grounded in trusted Thomson Reuters content. By embedding Deep Research into Newcode.ai, Robinson+Cole continues to build on its deliberate, governance‑first approach to AI adoption while delivering meaningful, practice‑ready innovation for its lawyers and clients. “Innovation at Robinson+Cole is grounded in client service, security, and practicality,” said J. Michael Wirvin, Managing Partner of Robinson+Cole. “By incorporating Thomson Reuters’ Deep Research directly into Newcode.ai, we are providing our lawyers with advanced research capabilities in a secure environment fully controlled by the firm that aligns with our standards for data governance, accuracy, and responsible AI use. This integration reflects our continued focus on adopting technology thoughtfully to support our attorneys and deliver value to our clients.” The addition of Deep Research allows attorneys to: Perform sophisticated legal research using agentic workflows that mirror real‑world legal reasoning Receive structured, verifiable responses grounded in Thomson Reuters data Streamline research processes while maintaining rigorous quality and accuracy standards Work entirely within Robinson+Cole’s firm‑controlled AI environment  “Our integration of the Thomson Reuters’ Deep Research API with Newcode represents a defining moment in our AI strategy,” said Chief Data Officer Jim Merrifield. "We are incredibly proud to be the first firm to bring this capability to life—unlocking the power of trusted legal data directly within the workflows our lawyers and business professionals rely on every day. This is exactly how we maximize our technology investments: by connecting best-in-class data sources through APIs into a unified platform, so the technology meets our people where they work, enhances their judgment, and accelerates better outcomes for our clients.” Robinson+Cole’s AI program is guided by firmwide policies, mandatory training, and ongoing oversight to ensure responsible use of emerging technologies. The firm’s approach emphasizes measured adoption, strong information governance, and alignment with client expectations, rather than one‑off experimentation. This latest enhancement underscores Robinson+Cole’s commitment to remaining forward‑thinking in its use of technology, while ensuring that innovation serves the firm’s clients, lawyers, and long‑term strategic goals.

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Robinson+Cole Remains A “Best Place to Work in Connecticut”
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Robinson+Cole Recognized at 2026 Women, Influence & Power in Law Awards
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Robinson+Cole Recognized Across Practices and Regions with 46 Chambers USA 2026 Rankings
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Kate Dion and Natale DiNatale Examine the Legal Questions Raised By Sorsby Injunction

Education industry team chair Kathleen Dion and Labor Relations group chair Natale DiNatale discussed the potential ramifications on the NCAA and college athletes in the article, “NCAA to appeal Brendan Sorsby injunction. What it means and how it can win,” published in USA Today, June 8, 2026. Kate pointed out that the injunction is a temporary measure. “This decision is only a preliminary ruling and is subject to appeal. Unless it is overturned, the injunction preserves Sorsby’s opportunity to compete this fall while the underlying case proceeds and allows him to continue preparing for a potential NFL career. For the NCAA, the ruling raises questions about the extent to which courts may review and potentially limit the enforcement of eligibility and competitive-integrity rules in individual cases.”  She continued, “It is also important to recognize that this is one state trial court decision, not a final decision on the merits, and thus its precedential value may be limited. While the court found that Sorsby demonstrated a probable right to the relief that he seeks on his breach of contract and other claims, which is a necessary element for obtaining a temporary injunction — the order does not appear to provide a detailed explanation of the court’s reasoning on that issue. As a result, many of the legal questions raised by the case are likely to remain the subject of further litigation and possible appellate review.” Discussing the foundation of the claim, Natale said, “The underlying dispute looks like a claim that the NCAA failed to accommodate a disability (e.g. an ADA claim based on a gambling addiction). But, it was brought as a breach of contract claim. A contract claim can be brought and maybe kept, in state court, which is likely a friendlier forum for this athlete.” Read the article.

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Erica Kerstein Brings Credibility and Business Perspective to New Role as Practice Group Chair

Insurance + Reinsurance group chair Erica J. Kerstein was featured in a Law.com column titled, “How I Made Practice Group Chair,” published on April 15, 2026. In the article, Erica discusses her new role as a practice group chair and how it has expanded her insight into not only the firm’s strategic vision and goals, but the reality of running a business and ensuring that current planning aligns with future goals. “The role provides a window into how individual practices fit into the firm’s overall strategy,” said Erica. “You’re thinking not just about today’s matters, but about where clients are headed, how the industry is changing, and how the firm positions itself to meet those needs.” In addition, Erica also identified “…strengthening client relationships, investing in our people, and staying ahead of emerging issues—particularly around technology and artificial intelligence in the insurance space…” as key priorities for the practice. Read the article.