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Treasury Department and Other Federal Agencies Issue Statement of Principles Concerning Carbon Credits

Today, the Treasury Department and other federal agencies (including the Agriculture Department and Energy Department) issued a joint statement identifying seven principles that should be applied in the voluntary carbon...more

EU Regulators Announce Greenwashing Investigation of 20 Airlines

The European Commission and EU consumer authorities have sent letters to 20 airlines “identifying several types of potentially misleading green claims,” focusing on “claims made by airlines that the CO2 emissions caused by a...more

NY AG Launches Greenwashing Lawsuit Against Beef Producer

Recently, the New York Attorney General filed a lawsuit against the American subsidiaries of JBS Group, the Brazilian-based beef producer, asserting that JBS had “violat[ed] New York's consumer protection statutes” through...more

European Court of Human Rights Declares Switzerland Failed to Adequately Address Climate Change

Today, the European Court of Human Rights issued a decision holding that Switzerland violated the human rights of its citizens by failing to adequately protect them from climate change. Specifically, the Court held that...more

SEC Approves Sweeping New Climate Disclosure Rule: Key Takeaways

The Securities & Exchange Commission ("SEC") issued its long-awaited final rule concerning climate disclosures, entitled “The Enhancement and Standardization of Climate-Related Disclosures for Investors” (“Climate Disclosure...more

Ten States Sue to Block SEC Climate Disclosure Rule Before the Ink is Dry

On the same day that the SEC issued its long-awaited rule on climate disclosures, ten states (West Virginia, Georgia, Alabama, Alaska, Indiana, New Hampshire, Oklahoma, South Carolina, Virginia, and Wyoming, which are all...more

SEC Issues Long-Awaited Climate Disclosure Rule

Today, after nearly two years of anticipation, the SEC finally enacted a climate disclosure rule on a 3-2 party-line vote by the SEC Commissioners. As described by SEC Commissioner Lizarrage, “[b]y requiring registrants to...more

SEC Expected to Drop Scope 3 GHG Emissions Disclosure Requirements From Final Climate Rule

Since the SEC proposed its climate disclosure rule in March 2022, the rule has been subject to significant public criticism and comment--particularly from business groups and conservative legislators who have questioned the...more

ExxonMobil Files Lawsuit to Block Shareholder Proposal Concerning Greenhouse Gas Emissions

Over the past few years, activist investors have submitted a number of shareholder proposals to major fossil fuel companies concerning issues relating to climate change. Recently, two such investors submitted a proposal...more

Democratic Senators Criticize Proposed SEC Disclosure Rule for Scope 3 Greenhouse Gas Emissions

On January 24, 2024, Senators Tester (D-Montana) and Sinema (I-Arizona) submitted a letter to the SEC concerning the SEC's proposed “Climate Disclosure Rule,” which would mandate, among other things, disclosures of greenhouse...more

Delaware Court Significantly Limits the State of Delaware's Climate Change Lawsuit Against Major Fossil Fuel Companies

On January 9, 2024, a Delaware state court judge issued his opinion on the various motions to dismiss filed in the case brought by the State of Delaware against the major fossil fuel companies. (This case is one of...more

Energy & Sustainability Litigation Updates — November 2023

Federal Regulatory Developments - On September 20, 2023, the SEC approved amendments to the “Names Rule,” which had initially been proposed in May 2022. This rule requires investment funds to “adopt a policy to invest at...more

Gov. Newsom Signs California Climate Disclosure Bills, Although Expressing a Degree of Skepticism Concerning Timing and Cost

On October 7, 2023, Governor Gavin Newsom of California signed into law two climate disclosure bills passed by the California Legislature. These laws now require that "by January 1, 2025 . . . businesses with total annual...more

Congressional Democrats Pressure the SEC to Maintain a Robust Climate Disclosure Rule, Including Scope 3 Emissions

Yesterday, September 26, 2023, Senator Elizabeth Warren (D-MA), along with six other Democratic Senators and eighteen Democratic Congressmen, sent a letter to SEC Chairman Gensler concerning the SEC's proposed climate...more

California Compels Disclosure of Greenhouse Gas Emissions by Major Companies Operating in California

Earlier this month, Governor Newsom announced his support of a sweeping climate bill enacted by the California legislature that would compel major companies operating in California to disclose their greenhouse gas emissions. ...more

SEC Re-Affirms Commitment to Climate Risk Disclosure Rule

On September 12, 2023, SEC Chairman Gensler testified before the Senate concerning a number of significant issues for the SEC. Among them was the SEC's still-pending rule on climate risk disclosures, which was first proposed...more

Energy & Sustainability Litigation Updates - August 2023

Public media reports have stated that the SEC’s Enforcement Division has been “sen[ding] document requests, including subpoenas” to asset managers in connection with ESG marketing. Apparently, these actions by the SEC’s...more

Montana Judge Rules That Youth Plaintiffs' Right to a Healthy Environment Includes Consideration of the Impact of GHG Emissions...

Today, a state court judge in Montana issued a long-awaited ruling in which the court found that the "Plaintiffs have a fundamental constitutional right to a clean and healthful environment, which includes climate as part of...more

House Republicans Issue Letters to Major Asset Managers Concerning Potential Antitrust Violations Allegedly Caused by ESG Policies

This week, Congressmen Jim Jordan (R-OH), Thomas Massie (R-KY), and Dan Bishop (R-NC), sent a letter on behalf of the House Committee on the Judiciary to three major asset managers and two non-profit organizations (the...more

EPA to Announce Proposed Regulation To Control GHG Emissions From Power Plants

It has been publicly reported that the Biden Administration's EPA will shortly "announce limits on greenhouse gas emissions from power plants that could compel them to capture the pollution from their smokestacks."  In...more

Energy & Sustainability Litigation Updates — March 2023

State and Local ESG Regulation. Despite recent public statements by notable Republican federal officials, including an SEC Commissioner, that have expressed considerable skepticism towards the SEC’s proposed ESG...more

Energy & Sustainability Litigation Updates — February 2023

Regulatory Developments - During the past several weeks, there have been a couple of notable developments in connection with the SEC’s proposed climate disclosures rule, “The Enhancement and Standardization of...more

Caremark Liability Following the SEC’s New ESG Reporting Requirements

Recent developments in the Court of Chancery concerning a corporate board’s duty to monitor and provide oversight over a corporation’s operations, so-called Caremark claims, are likely to intersect with the Securities and...more

Republican SEC Commissioners Continue to Criticize Proposed Climate Disclosures

Last week, SEC Commissioner Peirce delivered a lengthy speech at the American Enterprise Institute, in which she extensively criticized the climate disclosure rules proposed by the SEC. Her critique deliberately extended...more

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