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New EPA Positions Reflected in Sweeping Rollback of Greenhouse Gas Regulation

The Environmental Protection Agency ("EPA") proposed a rule that would rescind the 2009 Endangerment Finding, citing a new interpretation of the relevant section in the Clean Air Act ("CAA"), a lack of clear congressional...more

EPA Proposes Repeal of Greenhouse Gas Standards for Power Plants

On June 11, 2025, the U.S. Environmental Protection Agency ("EPA") issued a proposed rule to repeal all greenhouse gas ("GHG") emissions standards for fossil fuel-fired electric generating units ("EGUs") under § 111 of the...more

The Climate Report | Second Quarter 2025

Trump Paves Way for Coal Renaissance and Targets State Climate Change Efforts - In early April, President Trump issued several presidential actions to revive the coal industry, including rolling back environmental...more

Environmental Groups Sue New York to Implement Greenhouse Gas Reduction Law

On March 31, 2025, a coalition of environmental groups in New York filed a lawsuit to compel the New York Department of Environmental Conservation ("DEC") to issue regulations implementing the Climate Leadership and Community...more

Trump Paves Way for Coal Renaissance and Targets State Climate Change Efforts

In early April, President Trump issued several energy-related presidential actions aimed at reviving the coal industry. These actions could boost the domestic coal industry, including by rolling back environmental regulations...more

2024 GHG Reporting Deadline Extended

EPA has extended the reporting deadline under the Greenhouse Gas ("GHG") Reporting Rule for reporting year 2024 data from March 31, 2025, to May 30, 2025. Under the rule, owners and operators of facilities that are direct...more

EPA Puts "Holy Grail" of Climate Change in Crosshairs by Reconsidering Endangerment Finding and Other Regulations

The U.S. Environmental Protection Agency ("EPA") announced an agenda to revisit numerous regulations addressing the emission of greenhouse gases ("GHGs")....more

Montana Supreme Court Holds State Constitution Includes Protections Against Climate Change

Throughout 2024, young Americans from states like Oregon, California, and Hawaii turned to litigation, arguing that court intervention is necessary to protect them from climate change. The young plaintiffs spearheading these...more

EPA Announces Historic Deregulation

On March 12, 2025, the Environmental Protection Agency ("EPA") issued a flurry of press releases announcing its plan to rollback dozens of Biden-era, as well as earlier, environmental regulations. This historic move is part...more

New York Enacts Climate Change Law That Fines Companies for Historical Emissions

On December 26, 2024, New York enacted a law requiring certain energy companies to contribute cumulatively $75 billion to a climate "superfund" over the next 25 years....more

The Climate Report | Fourth Quarter 2024

New ESG regulations are expected to have a significant impact on disclosure and governance obligations for EU and non-EU companies alike, including extensive sustainability reporting and due diligence requirements on...more

EPA's HFC Emissions Reduction and Reclamation Program Finalized

On September 23, 2024, the U.S. Environmental Protection Agency ("EPA") announced a final rule under the American Innovation and Manufacturing Act of 2020 ("AIM Act") establishing a new program overseeing hydrofluorocarbons...more

An Update on Recent U.S. Mobile Source Air Emissions Regulations and Ongoing Challenges

As noted in previous editions of The Climate Report, in recent months, the United States Environmental Protection Agency ("EPA"), Federal Highway Administration ("FHA"), and California Air Resource Board ("CARB") have imposed...more

The Climate Report | Third Quarter 2024

REGULATORY ISSUES & UPDATES - Update on Australia's New Climate-Related Financial Disclosure Regime - Australia's mandatory climate-related financial disclosure regime is inching closer to implementation after the proposed...more

The Climate Report | Second Quarter 2024

REGULATORY ISSUES & UPDATES - Recent Evolution of the European Regulatory Framework on Greenwashing - Two new Directives adopted by the EU in 2024—the "Empowering Consumers Directive" and the "Green Claims...more

Federal Courts Vacate the U.S. Federal Highway Administration's GHG Performance Rule for On-Road Emissions on the National Highway...

The U.S. Federal Highway Administration's ("FHWA") new rule establishing a performance-based method for measuring greenhouse gas ("GHG") emissions that are associated with transportation on the National Highway System was...more

U.S. EPA Increases the Heat on Coolant Enforcement

On April 10, 2024, the U.S. Environmental Protection Agency ("EPA") filed a complaint for civil penalties against USA Wholesale, Inc. for the illegal import of hydrofluorocarbons ("HFCs"). HFCs are greenhouse gases used...more

Vermont Law Requires Energy Companies to Pay for Climate Change Damage

Vermont passed a first-of-its-kind law requiring energy companies to pay for part of the damages from extreme weather events, but the law likely will face legal challenges....more

EPA Finalizes Rules to Regulate Pollution from Fossil Fuel-Fired Power Plants

On April 25, 2024, the Environmental Protection Agency ("EPA") finalized four rules to regulate pollution from fossil fuel-fired power plants. EPA's stated goal was to provide a framework on which power plants can rely for...more

Enhanced Sustainability Requirements for Federal Contractors

On April 22, 2024, the U.S. government issued a final rule ("Rule") to restructure and update the Federal Acquisition Regulation ("FAR") to implement a requirement for agencies to procure sustainable products and services to...more

EPA Finalizes New Emission Standards for Heavy-Duty Vehicles

The U.S. Environmental Protection Agency ("EPA") finalized the strictest-ever emission standards for heavy-duty vehicles. On March 29, 2024, EPA announced new emission standards for heavy-duty vehicles for model years 2027...more

U.S. Federal Highway Administration Enacts GHG Performance Rule for On-Road Emissions on the National Highway System

The U.S. Federal Highway Administration's ("FHWA") new rule establishing a performance-based method for measuring greenhouse gas ("GHG") emissions that are associated with transportation on the National Highway System ("NHS")...more

The CFTC Proposes "Guidance" for Derivatives Markets on Listing Voluntary Carbon Credit Derivatives

In Short - The Background: As voluntary carbon credits ("VCCs") have grown in popularity, questions about their integrity and quality have arisen for investors and among regulators and lawmakers. For this reason, many have...more

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