News & Analysis as of

Climate Change Comment Period

Cozen O'Connor

AGs Clash over EPA Rollbacks, Net-Zero Standards

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Illinois AG Kwame Raoul co-led a coalition of 17 Democratic AGs, the city of Chicago, New York City, and the California Air Resources Board, in filing comments opposing the EPA’s proposal to repeal the 2024 Mercury and Air...more

Troutman Pepper Locke

Clarity on California’s Climate Disclosure Rules Could Be on the Horizon

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As the January 1, 2026, deadline to make the first required disclosure under California’s landmark climate laws approaches, the California Air Resources Board (CARB) has announced that it will host another virtual public...more

Baker Donelson

California's Climate Laws: CARB Sets the Stage, but Final Rules Delayed

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California is gearing up to implement and enforce two groundbreaking climate disclosure laws – the Climate Corporate Data Accountability Act (CCDA) and the Climate-Related Financial Risk Act (CFRA). In July 2025, in lieu of...more

Ropes & Gray LLP

California Air Resources Board Announces Second Virtual Public Workshop – Thirteen Days to Go

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Late yesterday, the California Air Resources Board scheduled a new virtual public workshop. The workshop will be held on Thursday, August 21 at 9:30 a.m. Pacific Time. More information on what will be covered at the workshop...more

Haynes Boone

EPA Proposes Repeal of Legal Foundation for Greenhouse Gas Rules

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The U.S. Environmental Protection Agency (EPA) has proposed a major shift in regulatory policy—to rescind the agency’s 2009 “Endangerment Finding” and to repeal all resulting emission standards for new motor vehicles and...more

Jones Day

EPA Initiates Rulemaking to Eliminate the 2009 GHG Endangerment Finding

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The U.S. Environmental Protection Agency ("EPA") proposes rescission of the 2009 Endangerment Finding, which underpins greenhouse gas regulation under the Clean Air Act....more

Stark & Stark

Navigating the Proposed REAL Regulations for New Jersey Commercial Landlords

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On August 5, 2024, the New Jersey Department of Environmental Protection (“NJDEP”) introduced substantial climate change regulations called Resilient Environments and Landscapes (“REAL”). Public comments were accepted through...more

A&O Shearman

UK Financial Markets Standards Board transparency draft statement of good practice on the governance of sustainability-linked...

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The Financial Markets Standards Board has published a consultation on its transparency draft of its statement of good practice on the governance of sustainability-linked products. SLPs are products whose financial and/or...more

Latham & Watkins LLP

CARB Will Not Fully Enforce California’s Climate Corporate Data Accountability Act in 2026

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CARB will not penalize reporting entities for incomplete Scope 1 and 2 emissions disclosures under SB 253, irritating lawmakers and raising the specter of oversight hearings....more

Fenwick & West LLP

California Air Resources Board Solicits Input on Implementation of SB 253 and SB 261 Climate Disclosure Laws

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On Monday, the California Air Resources Board (CARB) issued an Information Solicitation to Inform Implementation of California Senate Bills 253 and 261, as amended by SB 219....more

Troutman Pepper Locke

CARB Solicits Public Input on Greenhouse Gas and Climate Risk Disclosure Laws

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On December 16, 2024, the California Air Resources Board (CARB) requested public feedback to “help inform its work to implement” the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk...more

Greenbaum, Rowe, Smith & Davis LLP

New Jersey DEP’s Resilient Environments and Landscapes (REAL) Regulations: An Overview of the Proposed Rulemaking and Its Impacts...

The New Jersey Department of Environmental Protection (NJDEP) is immersed in one of the most impactful rulemaking proceedings in the state’s history in an effort to implement regulatory changes to address and mitigate the...more

Foley Hoag LLP - Energy & Climate Counsel

New York State Solicits Comments on the Proposed Scope of the 2025 State Energy Plan

In September 2024, the New York State Energy Planning Board released a Draft Scope of the New York State Energy Plan (the “Draft Scope”) for public comment. The State Energy Plan, originally published in 2015, is guided by...more

Foley Hoag LLP - Energy & Climate Counsel

NYPA Releases Draft Renewables Strategic Plan, Invites Collaboration with Private Developers

On Tuesday, October 8, 2024, the New York Power Authority (“NYPA”) released its draft 2025 Renewables Strategic Plan (the “Draft Plan”) and invited public comment. The 2023-24 New York State budget granted NYPA expanded...more

Sullivan & Worcester

MEPA Issues Straw Proposals to Update Climate Resiliency and Greenhouse Gas Policies – Comments Due September 16th

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The Massachusetts Environmental Policy Act (MEPA) Office in the Executive Office of Energy and Environmental Affairs (EOEEA) has floated two straw proposals (available here) outlining conceptual frameworks to update the 2021...more

Husch Blackwell LLP

OSHA Publishes New Heat Safety Standard

Husch Blackwell LLP on

On August 30, 2024, OSHA formally published its heat safety standard for indoor and outdoor work in the Federal Register, starting a 120-day public comment period. As explained in our previous blog post, the new rule is...more

Bennett Jones LLP

In Case You Missed It… The Comment Period on The Federal Government Consultation on Plastic Waste and Pollution from Textile and...

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Environment and Climate Change Canada (ECCC) published a consultation document on July 4, 2024, seeking input from stakeholders on a proposed roadmap for addressing plastic waste and pollution from the textile and apparel...more

Bergeson & Campbell, P.C.

USDA Publishes RFI on the Production of Biofuel Feedstocks Using Climate-Smart Practices

The U.S. Department of Agriculture (USDA) seeks public input on procedures for the quantification, reporting, and verification of the effect of climate-smart farming practices on the greenhouse gas (GHG) net emissions...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Foley Hoag LLP - Energy & Climate Counsel

IRS Issues Guidance and Requests Comment on Provisional Emission Rate Process for Hydrogen Tax Credit

On April 10, 2024, Department of Treasury and the Internal Revenue Service (collectively, “IRS”) issued further guidance on the “Provisional Emission Rate” or “PER” process for the Inflation Reduction Act’s (“IRA”) Hydrogen...more

Troutman Pepper Locke

FERC Initiates Inquiry into Capacity Allocation on Non-Contiguous Pipeline Segments

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On March 21, 2024, FERC issued a Notice of Inquiry (“NOI”) seeking additional information on whether the Commission should continue to allow interstate pipelines to package “high value” capacity with non-contiguous and...more

Davis Wright Tremaine LLP

EPA Seeks Comments on "Clean" Label for Construction Industry

Inflation Reduction Act pledged millions to label program intended to cut climate pollution linked to manufacturing of construction products and materials - The Environmental Protection Agency ("EPA") is seeking public...more

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

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The U.S. Department of the Treasury and the IRS on Dec. 22, 2023, released proposed regulations regarding the production tax credit (PTC) for hydrogen under Section 45V of the Internal Revenue Code, as enacted by the...more

Holland & Knight LLP

New York Drafts Policy for Evaluating Permitting Impacts on Disadvantaged Communities

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New York's groundbreaking Climate Leadership and Community Protection Act (the Climate Act) is known for being the country's most aggressive climate and clean energy statewide agenda. It calls for a mandated goal of a...more

Brownstein Hyatt Farber Schreck

EPA Proposes Significant Revisions to GHG Reporting Requirements in Subpart W

When the Environmental Protection Agency (EPA) launched the Greenhouse Gas Reporting Program (GHGRP) in 2009, the objective was to collect and publicly report greenhouse gas emissions data across certain industries. Through...more

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