News & Analysis as of

Comment Period Greenhouse Gas Emissions Climate Change

Cozen O'Connor

AGs Clash over EPA Rollbacks, Net-Zero Standards

Cozen O'Connor on

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

Troutman Pepper Locke on

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

Baker Donelson on

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

Ropes & Gray LLP on

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

Haynes Boone on

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

Jones Day on

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

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Sullivan & Worcester

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

Sullivan & Worcester on

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

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

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

Troutman Pepper Locke on

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

Holland & Knight LLP

Breaking Down the Section 45V Clean Hydrogen PTC Proposed Regulations

Holland & Knight LLP on

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

Holland & Knight LLP on

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

Foley Hoag LLP - Environmental Law

Proposed NEPA Rules Address Climate Change, Environmental Justice, and Efficiency of Environmental Reviews

On July 28, 2023, the Council on Environmental Quality (CEQ) proposed reforms to the National Environmental Policy Act (NEPA) regulations governing how federal agencies review the environmental effects of major federal...more

Eversheds Sutherland (US) LLP

ESG in the United States: A complex landscape

The United States is in the process of transitioning ESG disclosure from voluntary, market-led reporting to a regulatory-driven scheme, principally led by the US Securities and Exchange Commission’s (SEC) anticipated (but...more

Foley Hoag LLP - Energy & Climate Counsel

EPA Looks to Accelerate Electric Vehicle Adoption with New Vehicle Emission Standards

On April 12, 2023, the Environmental Protection Agency (EPA) proposed new pollutant emissions standards for light-duty and medium-duty vehicles and heavy duty vehicles.  The proposed rules set new, aggressive greenhouse gas...more

Cadwalader, Wickersham & Taft LLP

IOSCO Launches a Consultation on Compliance and Voluntary Carbon Markets Design

In November 2022, the International Organization of Securities Commissions (“IOSCO”) published two reports − one on Compliance Carbon Markets (“CCMs”) and one on Voluntary Carbon Markets (“VCMs”). IOSCO continues to seek...more

Faegre Drinker Biddle & Reath LLP

FAR Council Issues Proposed Climate Disclosure Rule for Government Contractors

Executive Order 14057 — “Catalyzing Clean Energy Industries and Jobs through Federal Sustainability” — made it clear that the Biden administration plans to use federal procurement policy to further its sustainability goals....more

WilmerHale

Biden Administration Proposes Climate Disclosure Rules for Federal Contractors

WilmerHale on

Companies considered to be “major” or “significant” US federal government contractors soon may be required to provide climate disclosures as part of the Biden Administration’s suite of policies designed to achieve net-zero...more

Venable LLP

White House Announces Federal Supplier Climate Risks and Resilience Rule - How This Will Impact Federal Government Contractors

Venable LLP on

In accordance with the Biden administration's Federal Sustainability Plan, on November 14, 2022, President Biden proposed the Federal Supplier Climate Risks and Resilience Rule. The goal of the proposal, as described by the...more

Holland & Knight LLP

FERC's Proposed "Duty of Candor" Draws Significant Opposition

Holland & Knight LLP on

The Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking (180 FERC ¶ 61,052 (2022))(Proposed Rule) on July 28, 2022, that would impose a sweeping "duty of candor" across all energy industries...more

Bowditch & Dewey

Boston Proposes Zero Net Carbon Building Zoning Initiative

Bowditch & Dewey on

The City of Boston and the Boston Planning and Development Agency (“BPDA”) have put forward a new proposal, known as the zero net carbon building zoning initiative, which would require that newly constructed buildings over...more

Holland & Knight LLP

EPA Moves Ahead on Green Bank: Opportunity to Weigh In Is Now

Holland & Knight LLP on

The Inflation Reduction Act (IRA) authorized the Greenhouse Gas Reduction Fund (GGRF), a $27 billion clean energy deployment bank housed at the Environmental Protection Agency (EPA). The GGRF is the largest single pot of...more

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