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★ Independent · Editor-Owned · No Paraphrase ★ Burn the Playbook "The newsletter DC reads and hopes you don't." | |||
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Imagine hiring a lawyer to sue the guy who poisoned your well, then finding out he also represents the guy who poisoned your well. You would fire him before lunch. In Washington, that arrangement is not a scandal. It is a business model, and it is fully disclosed, in writing, on a government website, every quarter.
The firm is Holland & Knight. The chemical is PFAS, the "forever chemical" family that is in the blood of nearly every American. On one side of the table sits Chemours, the DuPont spinoff that makes GenX. On the other side sit the cities and water utilities that have to pay to get it out of your drinking water.
Same firm. Same lobbyist. Same quarter. Same word on the form.
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The Filings Say It in Plain English
$380,000 — what Chemours paid Holland & Knight in 2025 to lobby Congress, EPA, and the Army Corps on "Superfund; Clean Air Act; PFAS water regulations" — per Senate LDA, Q4 2025 report, Jan 2026
$210,000 — Chemours's payments to the firm in the first half of 2026 alone, with "West Virginia permitting" added to the PFAS line in the second quarter — per Senate LDA, Q2 2026 report, Jul 2026
$520,000 — what the American Chemistry Council, the chemical industry's trade group, paid Holland & Knight in 2025 for "chemical regulation" and toxic-substances law, plus $260,000 more through June 2026 — per Senate LDA, Q4 2025 report, Jan 2026
$30,000 a quarter — what the City of Aurora, Colorado paid the same firm in 2025, with "PFAS" listed as a lobbying issue and Richard Gold, the same lobbyist on the Chemours account, listed on the city's account — per Senate LDA, Q4 2025 report, Jan 2026
H.R. 1267 — the Water Systems PFAS Liability Protection Act, which shields utilities from Superfund cleanup costs so polluters pay instead, lobbied by Holland & Knight for Florida's Tohopekaliga Water Authority at $20,000 a quarter — per Senate LDA, Q3 2025 report, Oct 2025
95 local governments share a congressional lobbying firm with a chemical trade association; 34 of them are Holland & Knight clients — per F Minus and Mothers Out Front, Jun 16, 2026
Start with what is proven, because the proof is the point. Every number above comes from LD-2 forms Holland & Knight signed and filed with the Secretary of the Senate. Nobody leaked anything. The firm wrote "PFAS water regulations" next to Chemours and "PFAS" next to Aurora, listed Richard Gold on both, and mailed it in.
Aurora is not an abstraction. It is a city of 400,000 people east of Denver whose water department shut down wells with elevated PFAS and runs the rest through activated carbon to stay under the federal limit. That filtration costs money. The people paying it are ratepayers, which is to say you, if you live there.
Chemours is the company that spun out of DuPont carrying the Teflon liabilities. In June 2023, it agreed to pay $592 million, half of a $1.185 billion settlement with public water systems across the country, for PFAS in drinking water. It makes GenX, the chemical its Washington Works plant on the Ohio River has been discharging past permit limits, which is why "West Virginia permitting" showed up on the lobbying form this summer.
What the Chemical Side Got
Here is what happened while the firm held both accounts. On May 20, 2026, the Trump EPA published a proposal to rescind the 2024 drinking water limits on four PFAS, including GenX, and to push the compliance deadline for the two most notorious ones, PFOA and PFOS, from 2029 to 2031. Two weeks later, the Fourth Circuit threw out an injunction that had barred Chemours from discharging GenX beyond its permit at Washington Works.
I am not telling you Holland & Knight caused either outcome. That is not proven and I will not pretend it is. What is proven is that Chemours paid the firm to work "PFAS water regulations" at EPA in every quarter leading up to the rollback, and that the rollback is worth real money to Chemours: the Biden-era rule was estimated to deliver $1.5 billion a year in health benefits, and someone was going to be asked to pay for those benefits.
The water utilities were fighting to make sure that someone was not them. That is what H.R. 1267 is: a bipartisan bill from Marie Gluesenkamp Perez and Celeste Maloy that says a utility that passively receives PFAS should not be treated like the factory that made it. Holland & Knight lobbied it for Toho Water. Then it went back across the hall and billed the factory.
Why This Is Legal, and Why That Is the Problem
Lobbying is not law practice. The Lobbying Disclosure Act has no conflict-of-interest rule. Craig Holman of Public Citizen told The New Lede that if a firm builds a firewall between lobbyists on different sides, it is "not necessarily breaking any legal obligations." Holland & Knight told The Guardian in March it follows "rigorous ethics and conflict-review procedures" and that representing a client does not mean advocating on every policy issue.
Take that at face value and read the Aurora form again. The firewall is Richard Gold, and he is on both sides of it. Jenny Zimmer of Mothers Out Front put it the way a normal person would: you don't hire the same lawyer to prosecute and defend the same case.
I spent twenty years watching firms do this and calling it sophistication. The trick is not that they lie. The trick is that they tell you, on a form nobody reads, and count on the fact that a city council in Colorado is never going to pull the Chemours filing. Cities hire the big firm because the big firm knows everybody. The big firm knows everybody because it works for everybody. That is not access. That is the polluter's access, resold to you at $30,000 a quarter.
Add it up from the filings: Chemours and the ACC paid Holland & Knight about $1.37 million across 2025 and the first half of 2026. Aurora and Toho paid about $240,000 over the same stretch. When the two sides collide, the firm does not have to pick. The invoice already did.
So here is the ask, one only: if you sit on a city council, a water board, or a county commission, pull your lobbying firm's client list at lda.gov and reply to tell us who else they work for.
Sources
F Minus / Mothers Out Front, "Congressional lobbyists playing both sides on PFAS pollution" — report naming Holland & Knight, Alcalde & Fay, CGCN, Mehlman, Marshall & Popp; 95 local governments, June 2026. source
The New Lede (Brian Bienkowski) — coverage of the report, Holman and Zimmer quotes, Holland & Knight's prior statement to The Guardian, June 2026. source
Florida Phoenix — Florida local governments sharing lobbyists with chemical clients; Browning quotes, June 2026. source
Senate LDA, Holland & Knight for The Chemours Company, Q4 2025 — $80,000; "PFAS water regulations"; lobbyists Gold and Karakitsos; EPA and Army Corps contacted, January 2026. source
Senate LDA, Holland & Knight for Chemours, Q1 and Q2 2026 — $110,000 and $100,000; "West Virginia permitting" added, April and July 2026. source
Senate LDA, Holland & Knight for City of Aurora, CO, Q4 2025 (termination) — $30,000; "PFAS"; lobbyists Hettinger and Gold, January 2026. source
Senate LDA, Holland & Knight for Tohopekaliga Water Authority, Q3 2025 — $20,000; H.R. 1267, October 2025. source
Senate LDA, Holland & Knight for American Chemistry Council, Q4 2025 — $130,000 per quarter; chemical regulation and TSCA implementation, January 2026. source
EPA, Proposed PFAS Rescission Rule — rescinding limits for PFHxS, PFNA, HFPO-DA (GenX) and hazard-index mixtures; Federal Register May 20, 2026; comments closed July 20, 2026. source
Chemical Processing — Fourth Circuit vacates Chemours GenX injunction June 3, 2026; PFOA/PFOS deadline moved 2029 to 2031; $1.5 billion benefit estimate, June 2026. source
ASDWA — H.R. 1267 reintroduced by Reps. Gluesenkamp Perez and Maloy, shielding water systems from CERCLA PFAS liability, February 2025. source
Chemours press release — $1.185 billion PFAS settlement with U.S. water systems; Chemours share $592 million, June 2023. source
CBS Colorado — Aurora Water shut down wells with elevated PFAS and uses granular activated carbon treatment, May 2024. source
Burn Notice: When the same lobbyist is paid by the company that made the chemical and by the city paying to filter it out, the city is not buying influence, it is renting the polluter's.
— Michael
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