Okay. Good afternoon, everybody. Thanks for joining us this afternoon. As many of you know, the US Supreme Court recently passed several rulings impacting federal agencies, including one in particular known as Loper Bright. And this has injected some uncertainty into the marketplace as investors are scrambling to discern the ultimate impact, or I guess I should say, the potential impact of the earning streams of the publicly traded companies. And one such company under our coverage list is Montrose Environmental, which offers environmental solutions across a variety of end markets and applications. So we're happy to have them here to discuss this whole dynamic in some detail.
We're pleased to have with us today, CEO Vijay Manthripragada, CFO Allan Dicks, and the Chief Commercialization Officer, Todd Grosshandler. Gentlemen, welcome, and thank you for joining us.
Thanks so much for having us, Tim. And Tim-
You bet. So I'd like to start off with just a general question, then we can get into some, some of the details. But just to start out, my question is, do you think the Supreme Court's recent overturning of the Chevron deference will impact your business?
That's a loaded question, Tim.
Yeah.
And one we're getting quite a bit of. No, but it's a great one. Because of the scope of Loper Bright, we believe most US businesses are likely impacted. But the bottom line for Montrose, which I wanna make sure we convey, is really kind of twofold. One, our short and long-term business outlook is unchanged, and we're staying the course. And two, and this may seem a little counterintuitive, there are likely additional future opportunities for us because of the regulatory complexity this is likely gonna introduce. And just to give you a little bit more color around why I'm making those two statements, Tim, what I understand the ruling actually does is ensure courts have final say over whether agencies are doing what Congress intended, right?
They have to respect the agencies on the science, but not defer to them. As we think about the court agency dynamic, that's been happening for a long time with the EPA. We here at Montrose are totally accustomed to this. This is kind of, in many ways, a normal course for us as we think about Waters of the United States or the Clean Power Plan, for example, how that unfolded and how we navigated that. You guys have seen, and that's—this, to us, feels like it's more into that. The other dynamic with the shift from Chevron to Skidmore is that we expect there's gonna be more power given to the state environmental agencies, and as that dynamic shifts to the states, Tim, that benefits Montrose.
The other point I wanna make sure I convey to you is because we're mostly private sector-oriented, we talked to about a dozen or so of our major clients, and what we heard from them is that they're also staying the course for all the reasons I just shared. And so given our clients are staying the course, given they aren't necessarily shifting and we're not seeing a shift in demand from them, and we expect there's potential upside in terms of more consulting demand for our business, we're remaining quite optimistic and positive about our outlook. And Todd, I don't know if you want to share additional color with Tim on-
Yeah.
What you heard from clients.
Yeah, no, thanks, Vijay. As Vijay said, you know, we reached out to a number of our key clients in a variety of the market segments, ranging from transportation and manufacturing to some of the chemical and some of the largest oil and gas producers in the world. And, you know, I think from the conversations I took away, there were, like, three key takeaways. You know, the first was the sentiments that they were really sharing with me was it's business as usual, and those are really their words. I think, you know, they conveyed that the planning and compliance strategies that they're implementing at these larger companies are, you know, the federal oversight is really a backstop and really not the key driver for their immediate compliance or enforcement activities.
And then just really, you know, given the multiple stakeholders they have from the, you know, public sentiment to the overall sustainability commitments to the states and their investors, that they continue to really see strong drivers for them in this market. You know, they did convey that they saw, you know, the transformative element of this regulation was really around helping ensure clarity in environmental regulations, and really to minimize the whipsaw that they see occurring from one administration change to the next, and to also minimize, you know, novel interpretations of some of these environmental regulations. So really, in short, you know, the feedback that we got was they're really not slowing down any of the services in any of these markets where we play.
Thank you both. That is very clear. You know, what you just said, nothing changing today or tomorrow or for the foreseeable future. Business as usual, I think that's the big takeaway there. And appreciate all the detail, and I have this whole list of questions, but we want a whole five minutes before I need to now go off.
You wouldn't be Tim if you didn't.
Exactly. So let's, I'd like to follow up on just a couple of those things. Number one is, Vijay, you know, you said it could potentially give more power to states. I was wondering if we could double-click on that, 'cause I've spent the last two weeks reading about this, and I don't, I'm not exactly clear on what that means, and I have a feeling that you could maybe elaborate a little bit more on that. If you could, if not, no worries. And then, Todd, after that, I was wondering if you could. You know, my impression of getting rid of Chevron was it was gonna increase the whipsaw, because now there's this uncertainty going to courts. You know, one judge says one thing, one says another.
It's not deferring to the regulator, so there's no federal, you know, one voice. It's like, I thought it would increase uncertainty and the whipsaw effect. But in your mind, because everyone's gonna have to bring more data to this effort, it might actually ensure clarity of the right, 'cause I thought that was interesting. Just wanted to make sure I heard you correctly there, so I'll leave it to you guys to discuss those things.
Yeah. Todd, do you want me to start? And then,
Sure. Yeah.
Then you can jump in. So Tim, let me share, and I'll talk about this in the context of the state question as well, and this is jumping into what Todd was articulating. If you think about some of the concerns that folks have related to Chevron versus Skidmore, the idea is to follow the statutory guidelines prescribed by Congress, right?
Yep.
And what the reason our clients are kind of sharing their view that this should increase certainty, right? Is that non-enforcement or rollbacks of environmental regulations, which is one of the things we talked about with you when we kind of when we were going public in the Trump administration, right? That dynamic is also counter to the statutory guidelines. Does that make sense? So-
Yeah.
The statutes are pretty clear: You shall do X, and so it doesn't really give you a lot of choice as to what that means, right? Either you're gonna go more than that, in which case the courts are gonna say, "Nope," or you're gonna try to go less than that, in which case the courts are gonna say, "Nope." And it's that in-between path that increases the certainty for, for an operating entity like our clients. That's, that's really what that means, and I think it's important... Let me just step back. I think it's important to remember that the EPA's reason for existence, right, in a, in a grossly simplistic way, is to worry about, and regulate hazards in air, water, and soil.
Writ large, we expect the impact of Chevron will be where regulatory programs are premised on residual clauses within statutes, or where agencies are deriving authority outside of their customary statutory wheelhouse. And so you and I'll give you two examples of that, Tim, if you think about. And we're not drawing any judgment on whether these rules are good or bad, just as examples of where they may be outside of something that is normal course or what was intended by the statutes, the Pipeline Safety Administration or the SEC ruling on climate as two examples, right? We expect those are the types of rules that are gonna get challenged more.
But where the agency is exerting authority in its traditional wheelhouse, challenges will occur, like they have for decades, and stuff we've seen before, it's nothing new, but we expect the regulatory arc will remain. And so what I was alluding to is that not only do I think the areas in which Montrose is focused, will largely be similar, they may be modified on the margin because they get challenged on the, APA, not Chevron. But more importantly, even if, some of the rules related to specific compounds or molecules, are under pressure at the federal level, there are still states that have sub-substantive regulations, right?
So with PFAS, for example, 21 of our 50 states in the United States have rules or are in the process of implementing rules, some of which are more stringent than what's at the federal level. So if I'm an operating business, if I'm a private client like, like Montrose's clients, I have to address the state requirements anyway. And that's what I meant when I said the states. And now, if I'm operating in multiple states, I have to likely deal with the lowest common denominator. And so state authority is gonna increase, that benefits us. Complexity is gonna increase, that benefits us. And more importantly, I don't think the long-term regulatory arc on these specific compounds or molecules really changes for us all that much.
Okay, great. Thank you. Todd, did you have any thoughts or did BJ kind of address it?
Yeah, no, I think he covered it really well. I think the only thing I would add is, you know, the time it's gonna take for these challenges to get through the court system is gonna take a long time. And so I think as the clients that I talk to, as they're sort of thinking about their immediate and sort of near-term efforts, I think that it's their long-term outlook. Like, long term, the outlook is gonna be—there's gonna be real clarity. You're not gonna interpret the regulation differently just because it's a Democratic or a Republican administration. It's gonna be really, really clear. And so I think long term is where they will see the reduction in that whipsaw.
Okay. That's helpful. Thanks, thank you. You know, I'm wondering now, okay, so given everything that you just said, my next question is: How are you positioning the business to address heightened uncertainty around environmental regulations? It sounds to me like it's business as usual, but I'm gonna ask the question anyway. Is there anything different that you have to do now, in thinking about the Chevron deference gone, as you, you know, as we think about how you position your business?
I mean, Tim, uncertainty tends to benefit our business model, right? We've talked about this with you before, where complexity and uncertainty tends to drive our advisory and testing segments in particular. And so as we think about positioning, we may prioritize more of our advisory services in terms of where we allocate our attention or capital from an M&A perspective, and perhaps in select states where we see more opportunity as we see the power shift from the federal to the state governments. But our thesis is the same, and I just wanna make sure I'm very clear. We are not changing our path or our strategy, and our thesis is consistent for all the reasons we just talked about.
I think the other point that's important here, as it relates to uncertainty, is that our business is almost entirely anchored on regulations that have been around for decades, Tim. And these are regulations that have been challenged in courts over and over and over again. And so even though this is a big shift in the legal doctrine, we don't expect it to move much of what Montrose is based on. So for all those reasons, we're not shifting kind of our outlook, or our strategy, but in terms of where we emphasize parts of our segments or service lines versus others, that may shift over time as we see how this unfolds in the courts and how our clients react to that. Does that answer your question?
... Does. I actually was reading an article that said the Supreme Court hasn't relied on Chevron deference for an EPA ruling since 2014. So it sounds like this isn't like you said, your business isn't anchored on the regs that are maybe up for debate here. Like, a lot of the regs are probably the ones that have been around for decades and aren't gonna be challenged on that basis. So, definitely understood. I think it's interesting that you highlighted this advisory and testing opportunity for folks that don't know the business as well.
Why would heightened uncertainty potentially help that business? I mean, I think I have an idea, but for folks that don't know the business as well, I could imagine there being more uncertainty in the courts. "Hey, these 10 regs are being challenged. We need help, you know, navigating the business." Is that, you know, we need help understanding where the risk is in our business, you guys could help out with that, or is it something else? Why might advisory and testing, you know, benefit from heightened uncertainty?
I'll give you, I'll give you kind of three historical examples, Tim, right? When we saw what happened with Waters of the United States and how the courts kind of processed that over time, when we saw the NEPA regulations, when we shifted from the Obama administration to the Trump administration, when we saw kind of the changes to the initial proposition related to the Clean Power Plan and the courts vacating that, all of that resulted in significant uncertainty for our clients. And our advisory business deals, exactly as you said, Tim, with those questions: What does this mean? Where are my risks? What should I do now? What should I plan for in the future? Does this impact my future planning process? What, how do I think about my existing permits? How do I think about future permitting requirements?
So we see substantive tailwinds on the advisory side as a result of that complexity and uncertainty, and oftentimes that results in tailwinds for our testing business, because now do I need to measure things differently? Do I need to report things differently? And then how does that flow into my permitting and assessment and risk management process? And those two are usually intertwined, and so we see a fair amount of that, and we've seen it before, and we certainly expect that to happen here. We're already seeing inbounds related to that.
The other part of this is, I think you know this, Tim, we support many of our clients with litigation related to environmental regulations and environmental impacts, and that part of our business is seeing a nice demand uptick as well.
Very, very clear. Thanks. You know, we've seen many articles highlighting expected challenges to things like PFOS, MCLs, or GHG emission caps for power plants or the Renewable Fuel Standard, just to name a few. What areas of your business do you think are more dependent upon specific regulations that may be challenged, relative to other areas of your business?
You know, look, as I noted earlier, Tim, the vast majority of our business is anchored on regulatory frameworks that have been validated over decades by the courts. So just as a quick reminder, our growth algorithm of 20% to 25% top-line growth, right about high single digits, 7% to 9%, organic and 10 to 15+, M&A driven, Tim, is what we talked about at IPO. That's the same as it's always been. That's unchanged. And so our outlook and our growth algorithm are the same as they've always been. We've been growing closer to 30% to 35% a year over the last couple of years, right?
Faster than our historical thesis, and that's because of the opportunities we've seen around methane and PFOS, which are a big part of that incremental and that accelerated growth that we've seen. And so it's not that our business is dependent on specific regs, but that accelerated growth driven by PFOS and methane. We think PFOS is an APA debate, not a Chevron deference debate. And so it's really around the administrative procedures by which the agencies make rules, and as I said earlier, that's par for the course for us. We see that all the time.
This is something that's been happening for decades. It's happened in the last couple of years, where the courts weigh in on whether the agency overstepped or didn't step properly on specific regulations. That was expected as it relates to both PFOS and methane, and that's progressing as per plan. And then on methane, the Supreme Court and Congress have already weighed in, and so we don't really expect, and our clients don't expect much to change there. There may be tweaks on the margin around specific thresholds. I mean, should it be 4 PPT or should it be 3 or should it be 6? But that doesn't really impact our outlook or our thesis.
And so if you, again, just reiterating what I was saying earlier, Tim, we've talked to our clients, they aren't changing our outlook. We're not changing our outlook either, and our business isn't dependent, and our, and our growth algorithm and our positioning, is not dependent on any specific regulation.
Yeah. I'm not sure the demand would change that much if it went up to 20 PPT, to be honest.
Right.
The point is, folks are still gonna have to plan for it. I want to touch on methane real quick. You know, what's your take on the specific air regulations, particularly those targeting methane? Your thoughts on the HON Rule, you know, which requires chemical producers to perform ongoing fence line monitoring to measure hazardous air pollutants?
I can jump in. Sure, sure. I think, you know, as Vijay mentioned in the, you know, given the 2007 ruling, the Massachusetts v. EPA, it really confirmed the EPA's authority to regulate greenhouse gases, including methane, under the Clean Air Act. And so, you know, we really see that this ruling is just not affecting those regulations. Additionally, the methane reduction funding as well as the measurement, quantification and taxing is written into the Inflation Reduction Act.
... And so since they're part of the statutes, you know, they just don't see that they can be declawed back. I think with the HON Rule, it's similar. You know, this is well-trotted ground. You know, these NESHAP s are well established regulatorily and have withstood scrutiny for decades and decades. And so we see no impact to the HON Rule either.
Got it. And you already said this, Vijay, but I got the question a lot from investors over the last couple of days, so I'm just gonna ask it again, just to be super clear. How should investors think about the impact from this Loper Bright ruling on your long-term financial targets, and can you remind us what those are?
So we are not changing our long-term financial targets, Tim. We are feeling as good and in some ways, we're kind of excited for some of the opportunities this brings for us, as I talked about. So just to reiterate what I said earlier, we expect to grow 20% to 25% top line a year, and we expect to continue seeing margin accretion over time. We believe organic will represent around 7% to 9% of that, and then the remaining 10% to 15% of that will be M&A driven. That thesis remains unchanged, and we're feeling as good as we were before this happened on what that outlook looks like for us.
Okay. Thank you. Just wanted to reiterate that. We'll pivot here a little bit. You know, I know PFAS is only one piece of a much broader sustainability services story at Montrose, but given the passage of, you know, those recent regs, this topic in particular represents a lot of the inbound investor questions, so I think we should spend a little time here. I also think digging into one issue might help investors build a framework for how to approach other environmental statutes that may be challenged in court. So with that in mind, you know, I'm recalling back to an expert call we did not that long ago, with former deputy assistant director at the EPA, who said, "One way or another, this PFAS issue is gonna have to be dealt with." Is that also your view?
Yes. Right, and we've gotten this question from many folks, Tim, so I'm not surprised you're fielding it as well. Look, it's the future is always very tough to predict, but I'll share. Let me share a little bit more detail as to why our outlook is, is unchanged and why, you know, as we kind of apply the framework internally to this situation or, or PFAS in particular, why we feel pretty good about where it stands. So I'll give you a couple of, couple of data points. One is, regulating contaminants or potential contaminants is what statutes ask the EPA to do. So, the courts may not like how the statutes were interpreted, but regulating them is not really in question. So this is, we believe this to be fully within the EPA's wheelhouse.
The other data point that I think is relevant here, which is important to note, is that this is a bipartisan issue, and it's been for a while. So whether it's red states or blue states, they've both been focused on it, and there's example after example that we've talked about with you in the past, Tim, and even recently, with what's currently in front of the committee, with the Clean Water Standards for PFAS Act, right, bipartisan. This is both a Republican and a Democratic issue, and as a result, we think that this is likely going to stick. And Todd alluded to this, the third variable that's really critical here is that this is not just about regulations, right?
This is also about litigation, legal risks that many potential clients may face or existing clients do face, shareholder concerns. And for companies operating again in states that have substantive regulations, which there are many, and/or international jurisdictions where there's many PFAS regulations, the regulatory landscape is complex, and it's not entirely predicated on the EPA. And so for all of those reasons, though the limits and the methodology the EPA used around PFAS will get challenged and likely will get challenged for a while, we expected that before the Chevron deference ruling. We are seeing that now, but it doesn't reduce the opportunity for us, Tim.
And so I know I sound like a broken record, but as you think about what this means for Montrose, a lot of this is par for the course as these new regulations get promulgated and as they get implemented, and we expected a lot of this, our clients did as well, and we've seen this before, but this was, this is. It doesn't change kind of the opportunity set for us or what we believe the broader industry outlook is gonna be, and as a result, our outlook just stays the same. We're not changing.
Yeah, and you don't sound like a broken record. I'm asking you the same question 10 different ways. There's so many ways to answer it, right? So I think, you know, I think it's really important to be very clear with investors of how, how you're looking about it, and I appreciate that. And to that point about expecting challenges, I mean, we saw the AMWA and the AWWA recently filed a challenge on these recently passed PFAS MCLs. So I'm wondering what you think about that challenge, if it has basis and, you know, if a judge were to vacate that standard, how you think about that, that target that you've talked about of doubling or tripling your PFAS revenue stream over the next several years?
Yeah, so those, some of those challenges are related to the municipal drinking water market, Tim, which has not been a focus of ours. So to answer your question specifically, our target of doubling over or more over the next three to five years, that is unchanged, right? For all the reasons we just talked about on this call. So we're feeling as good as we were before. And just as a quick reminder, PFAS for us is not just about treatment. There's advisory work, there's testing work... Those have been going on for years. Those are accelerating materially as a result of some of these questions that have come up.
And then, of course, there's treatment, and we've talked about that as well, given some of our proprietary technology. In addition to that, as it relates specifically to municipal drinking water, to give you a discrete example of what I meant by, our clients are not changing course, and their outlook is no different. We recently were contacted by a major municipal water utility. They reached out to us after Chevron, right? Given that that's the topic of this call.
Mm-hmm.
They were asking about our regeneration and our intellectual property around regeneration and concentration. The reason was because of the amount of media they expect to use, right? Whether it's 4 PPT, 6 PPT, 10, 15, 20, they know that they're gonna have to treat, and it's gonna be some threshold or some level, and they're gonna end up using a lot of media. So therefore, they're interested in what the technology could provide for them, either from a cost savings perspective, reduced waste perspective, right? For a host of reasons, that has implications for their sustainability goals and investor commitments, in addition to cost savings.
And so not only is that a market we historically hadn't addressed, but I cite that as an example to show you that clients aren't necessarily changing, and the potential upside for us, because of some of the confusion this has created, is real. So that type of challenge, again, just to kind of reiterate what I was saying before, was expected. We expect those will continue. There's gonna be a fair amount of that. We expect that courts will have various interpretations of what the statute said, right? It'll make its way through the appellate process. That takes years.
Operating businesses and clients that we deal with are gonna have to manage through that. That's gonna create tailwinds for our advisory and testing, but we haven't seen any pullback in demand for the treatment side either. In this specific instance, this opens up a set of opportunities we hadn't even really contemplated before, which is the drinking water utility market.
Yeah. So those MCLs are specific to public water utilities, but how much of that PFAS, you know, I have to kind of think about Montrose as being more leveraged to the industrial sites, airports, military bases. How much of that PFAS revenue target that you have in your head, I mean, you said doubled or more, but I'm sure you've got a number, right? So, you know, how much of that is based upon growth from the public water utility end market in particular?
In terms of what we shared about our historical outlook? Very little, right? That's just not a market we were very focused on. Our labs and our consulting businesses were helping the utilities kind of on the testing side, but it when we were talking about the opportunity ahead of us, the municipal drinking water piece of it was tiny, was de minimis.
Yeah, that's what I thought. So maybe we can talk about what is important on the PFAS side, which is, you know, these advisory testing, remediation projects. You know, as I think about the ones that you've won to date, how important were other factors, not regulatory, but like the technology, the resin regeneration, the super concentration, the on-site containment? How important were these factors in terms of helping you win those projects?
So our clients, to date, and before regulations were promulgated, before the Chevron ruling came out, our clients were primarily focused on anticipated regulations, so that outlook from their perspective hasn't changed. They were focused on litigation and risks that they were facing from a legal perspective. And then they were very focused on public relations, right? Communities in which they operate, and their commitments to those communities and/or pressure from communities in which they operate. So those are the primary drivers, and going back to my earlier comment, like, those haven't really changed. Right now, you have the regulations on top of that.
As they were thinking about balancing those variables and as they were thinking about the best solutions for their specific needs, specifically industrial clients, or departments of defense around the world, our technology, because it's more efficacious when you have multiple PFAS compounds, including short-chain PFAS compounds, because of our regeneration, which minimizes waste, and therefore minimizes cost and disposal risk. Those variables weigh pretty heavily, and they continue to be a key part of what drives the dialogue even after this ruling.
Got it. Okay.
If I could, hey, Tim, if I could just add one other point I think is important in that decision-making is really unique to Montrose, our integrated business model, where we have the consulting capabilities, the remediation capabilities, but we also have, you know, the dedicated internal PFAS laboratories, and then some experience, you know, doing some incredible projects globally. I think those really set us apart from a lot of folks that play in that space.
This is a comprehensive solution set and the technology that's helping you win rather than any specific set of regulations. Is that a fair statement, guys?
I think that's well said.
Okay. I mean, we've talked about the MCLs having potential upstream impacts to industrial sites or airports, because the MCLs just tackle public water utilities, but upstream impacts, potentially downstream impacts on landfills and wastewater plants. Gosh, I feel like I'm asking the same question again and again, but I'm gonna ask it: Do you think a judge vacating those MCLs would decrease demand for PFAS solutions from those folks upstream and downstream from the MCLs?
It again, the states have a significant amount of authority, Tim. And so, if there's challenges at the federal level, the state rules still have to be honored. And for all the reasons we cited earlier, we believe it's highly unlikely that the rules get vacated at the federal level. They're more likely to get challenged because of administrative procedures. And so it's gonna be more about limits as opposed to complete removal. But that belief aside, even if they did get vacated, because of the state rules and because of other pressures, the clients dealing with, say, 2 parts per trillion, which is the Illinois standard, right, not to mention all the other states that have rules, are gonna have to deal with how to treat the water before it gets to that level.
I would also think that if it were vacated, which sounds like it's a very low probability, that the other states that didn't have MCLs would all of a sudden be scrambling to establish something. They don't want, you know, this stuff in their drinking water either.
Right. But even if they didn't, right, our clients are operating in places where there are a lot of these rules already established, and as a result, whether it's landfills and landfill leachate or it's industrial production, the treatment requirements are substantive, and they're gonna need to be dealt with one way or the other.
Right. And as you said earlier, they'll probably... These large corporate clients are probably gonna adopt the lowest common denominator.
Yeah, 'cause they gotta cross multiple jurisdictions, right? So it's very hard to say, "My plant here, doesn't need to treat, but the one over there does.
Right. Yeah. Same thing on, you know, CERCLA. How do you think about that? Is it different in your view from the MCLs in terms of potentially going away or impacting your business in any way? It's my only question about CERCLA, but I wanted to touch on it while I have you.
Yeah, there's two. We've studied this a fair amount because we got this question a lot, Tim. I mean, right, so the recent PFAS regulations have kind of come in three flavors. There's the drinking water limits, there's the RCRA regs related to the waste disposal, and then there's the naming of PFAS and PFOA as hazardous compounds under CERCLA. The attorneys are probably better suited to answer this, but the way they've communicated it to us is that the statute on CERCLA is actually very clear, which is something to the effect of the EPA shall regulate compounds that may have an adverse effect on human health.
And so, they don't think there's gonna be much from a statutory perspective by which to challenge the designation. But, you know, the CERCLA designations always get challenged, and again, that's par for the course in this industry. But the Chevron ruling, they don't think materially changes that, the color of that, as it relates to PFAS.
Basically, been reading the same thing. The last question I have on PFAS, just, you know-
Tim, sorry. Sorry, just to add to that a little bit, and this is a little bit outside of what you asked, but it's related to CERCLA.
Yep.
The DoD has been testing for and working through PFAS for years, right? And this is something that's impacted us even through the Trump administration, right, into the Biden administration. They were following the CERCLA process and the hazardous waste process before the EPA designated PFAS and PFOA as CERCLA compounds. So just to give you a sense for the precedent here, right, again, the US Department of Defense was following the CERCLA process before the EPA designated these compounds CERCLA compounds.
So, I mean, again, right, will they get challenged? Of course, that's just what happens. Is it likely to get completely overturned? The legal community has shared with us that they find that very, very unlikely.
I mean, shall regulate compounds that may impact human health sounds pretty straightforward to me. We know these compounds impact human health. The question is just at, at what concentration, right? Like, the science is pretty clear on whether or not it impacts human health.
Right.
We're not arguing about that anymore. It's really just about-
Well, I think that's where, Tim, that's where a lot of the toxicology, that's where a lot of the science is gonna really fall, which is, you know, which ones do, do they? How much, at, at which concentrations do they? I think there's still a lot of questions there, right, which we, we help folks work through. So I don't wanna, I don't wanna make it sound definitive, but the word may is what's critical there, right?
Right.
They may. And so again, if you, if the purpose of the Chevron deference being overturned was to read the statutes more literally, you know, arguably that makes it much more clear exactly which way the court should go.
That's interesting. I haven't heard that. Yeah, that, that makes total sense. And, and you kind of hit on my next question, which is the DoD, you know, Loper Bright decision. Does this have any impact on the, the DoD's plan for PFAS site assessment, testing, remediation, anything like that?
So we've spoken to our contacts there, and again, similar to what Todd said earlier, they don't expect any change in their plans. The DoD is part of the federal government, but they weren't named in Loper Bright. So though they may be impacted, I think that's distinct from the agencies that were specifically named, Tim.
Mm-hmm.
That doesn't seem to be the intent. So no, we think this decision is likely not gonna have much of an impact on what the DoD's doing.
Got it. So, only a couple more questions. We're ripping through these guys. It's not gonna take the full hour. You know, just kind of turning the page to everyone's favorite subject right now, politics.
Oh, come on, don't go there, Tim, please.
Sorry. I only have one. You know, but I do think it's important 'cause stocks reacted on that Friday in late June, and it was just unclear how much of it was because of the debate and how that turned out versus the Supreme Court Loper Bright decision. You know, it all kind of came out on the same day, and everyone's trying to parse through this. So, you know, thinking about the other potential piece of what's impacting valuations and causing volatility in stock prices, could you just talk about how Montrose's business performed during that four-year period of the first Trump presidency? Were there headwinds related to agency funding or risk to deregulation back then that investors should be aware of for this cycle?
Yeah, we've gotten this question a ton, Tim, and-
Me too.
Yeah. And the bottom line is, we win either way. All right? I just wanna make sure that that's clear. And so I'll answer your question specifically, which is, look, we don't know what the outcome's gonna be, but we've seen this before, right? So we were founded in the Obama administration, that led to our IPO, which happened during the Trump administration, and we're now in the Biden administration. And in all instances, going back to your earlier questions, Tim, our growth algorithms in aggregate were largely unchanged.
The business trajectory was largely unchanged. If you think about our exposure to various geographies and states and then markets, it's by design, not meant to be, it's meant to be relatively insulated from kind of shifts in political cycles. And so whether it's a President Biden administration in the next couple of months, or a President Trump administration in the next couple of months, look, folks want the clean air or clean water is not a political issue, Tim, and we believe that to our core. And we've seen that as you, as you kind of look at our history and our performance.
We're staying the course, our outlook's the same, and we're candidly feeling really good given how we're positioned, regardless of what the presidential outcome is gonna be. It may shift a little bit of where we're focused in terms of which parts of our business may see more headwinds or tailwinds, but in aggregate, as we've done before, right, we think we're gonna churn right through it in a good way.
Got it.
Yeah, if I, if I could add to that, Tim, I think, you know, if you look at our performance during that Trump administration, we, we grew at a compound annual growth rate of, you know, around 23%, sort of consistent with our, with our thesis, and that is excluding the discontinued operations in CTEH, which came into the Montrose family at really at the end of that administration. So, so we've already been through this administration. We know what it looks like. We know how to navigate it, and, and we did well during that period.
Just one other note, you know, if you've been following, I'm sure you have, you know, the GOP plan, you know, they're really forward-leaning on energy production, and given our exposure to that end market, that would generally create some really nice tailwinds for our business as well.
We've heard that as well, that actually, you know, being forward-leaning on, on some of these industries that require a lot from you guys could actually be a positive thing. So I think that makes sense to me. You know, petrochemical, oil and gas, I mean, you guys operate here, and I wonder if that's part of the reason why you perform well, regardless of who's in office, is the fact that you are, you know, correct me if I'm wrong, but I think the split's like 80/20 private versus public clients. Is that right? And do you think that is one of the reasons why you perform well, regardless, because you're not so dependent upon, you know, funding it from any particular government or agency?
Yeah. I mean, we perform, we perform well, Tim, for two reasons. One, by design, our end market exposure, we, we try to make any given end market only about 10, 15%, right? So that may ebb and flow a little bit year in, year out, but on average, that's kind of our exposure. So if one of them surges and another one drops, right? If it's again, if it's a Biden administration, that doesn't happen, and other parts and other industries start seeing uptick, our aggregate performance is still very steady for that reason. The second dynamic that's critical, it's what I alluded to, even on the PFAS side, is that the states versus the federal is the, is the key variable there, right?
And that's true in Canada, with the provinces versus the federal, same with Australia, and certainly in Europe, each country operates a little differently, but they have a ton of authority. The federal government sets the baseline, but the states can then go further beyond that, in a way they deem fit. And that dynamic, as a result, insulates us from major whipsaws at the federal level. And then this recent ruling, as Todd alluded to in his comments, actually adds more certainty because the likelihood of a full-scale rollback or a lack of complete enforcement, which is one of the risks people have asked us about, that goes away now.
Because, again, if the statutes say you need to do it, you need to do it, no matter what your- what you may think, the statutes say.
Yep. So it actually protects some of these regulations in some ways from being-
Yes.
-rolled back.
Yes.
Which is not something that I thought about even reading through all this, so I'm glad we discussed that. Thank you, and CAGR of 23% through the Trump administration. That's a great data point. Thank you, Todd. Just one more question from me, which, shifting gears again, is your perspective on the SEC's role in oversight and Scope 1 and Scope 2 emissions reporting?
... Yeah, I can, I can take that. Sure. You know, I think, you know, VJ, you know, describes sort of the, the purpose of this Chevron. I think this is a, a, a real clear example of where it is gonna have an impact. And I think our collective view on our side is that this is a regulation that will be vacated, just based on reading the ruling, sort of understanding the historical Eighth Circuit rulings, which it's likely to be appealed to. You know, we just-- we don't really see a remedy, for this regulation, so it's, it's, it's likely to be vacated.
You know, but that said, you know, I think if you talk to clients who are reporting their Scope 1, Scope 2 emissions, in some cases, their Scope 3 emissions, this really doesn't save them anything. They're gonna continue to do it. They've already set up, in most cases, the processes to do it. And there's stakeholder pressure from states, there's stakeholders from investors, you know, people have made sustainability commitments, and they're being metriced by this reporting. We're even seeing banks, you know, sort of require this. So I think for those reasons, you know, it will probably be vacated, but people will likely continue reporting these.
Yeah. Tim, the other point, just to add to what Todd said, that's an example of regulation where, as it was coming down the pike, we had almost no exposure to it, right? So if it did, client asked us the question, it would be potential, testing or support from our perspective, but if it didn't, we didn't expect, it to be as sticky. And as a result, right, it's no impact to our outlook, which I think is the key point there.
Yeah, you didn't double down on the Scope 1, Scope 2 type?
Nope. Yeah, we had no real... It was not really included in any of our projections or outlook for this year and for foreseeable future.
We were reading similar things, Todd, by the way, that this one was a particular one that was potentially at risk. But that, that's good color. Thanks for sharing that. Guys, I'm through my question list. We're at 45 minutes here, but before I let you go, is there anything I didn't ask that you're getting a lot of questions on, or any additional things you'd like to say before I close out here?
No, just thank you, Tim, and thank you to all of those listening. I know this has been a topic that's been on everyone's minds, and we're kind of in the quiet period, so we haven't really been able to engage. But we look forward to kind of sharing our Q2 results and speaking more about our financial outlook for the rest of this year. And we can certainly answer any questions you have at that point. But thank you for bearing with us as we get through the quiet period and get into our earnings cycle. But, Allan and I are really excited about being with you in a couple weeks.
Yeah.
Thank you for allowing us to do this, Tim.
You bet, and thank you so much for joining. This was very educational. Appreciate your time today, and look forward to chatting with you guys in a couple weeks.
Thank you. Take care.
Thanks, Tim.
Take care. Bye.