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BOEM Floats Another Oregon Milestone: Final Wind Energy Areas Designated

On February 13, 2024, the Bureau of Ocean Energy Management (BOEM) designated two final Wind Energy Areas (WEAs) for the development of floating offshore wind energy projects off the southern coast of Oregon. This...more

Locke Lord Deep Dive: Examining Proposed Regulations on Expanded ITC Under Inflation Reduction Act

On November 22, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) published Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing long-awaited guidance and...more

Treasury Issues Proposed Regulations ‎‎on Expanded ITC Under Inflation Reduction Act, ‎Boosting ‎‎Storage, Offshore Wind

On November 17, 2023, the Internal Revenue Service (“IRS”) and the U.S. Treasury Department (“Treasury”) issued Proposed Treasury Regulations (REG-132569-17) (the “Proposed Regulations”) providing guidance and amending...more

MA, RI and CT Sign MOU to Support ‎Offshore ‎Wind, but Key Gaps Remain‎

Last week, at the American Clean Power Association’s Offshore WINDPOWER Conference, Massachusetts Governor Maura Healey announced that Massachusetts, Rhode Island, and Connecticut have entered into a first-of-its-kind,...more

Another Predicament in the Permian: ‎USFWS Proposes Renewed Endangered Listing for ‎Dunes ‎Sagebrush Lizard

On July 3, 2023, the U.S. Fish and Wildlife Service (“the Service”) proposed to list the dunes sagebrush lizard (Sceloporus arenicolus) (“DSL”), a species found only in southeastern New Mexico and west Texas, as an endangered...more

A Precautionary Tale: D.C. Circuit ‎Strikes Down Precautionary Principle Under the ‎Endangered ‎Species Act

On June 16, 2023, a three-judge panel of the U.S. Court of Appeals for the District of Columbia ruled unanimously that the National Marine Fisheries Service (“NMFS”), when faced with insufficient data, cannot rely on...more

Supreme Court Limits the Scope of ‎‎“Waters of the ‎U.S.”‎: What Developers Need to Know‎

The definition of the term “waters of the United States” (“WOTUS”) in the Clean Water Act (“CWA”), and the resulting scope of the jurisdiction of the U.S. Environmental Protection Agency (“EPA”) and U.S. Army Corps of...more

IRS Issues Guidance on the Domestic ‎Content Bonus Tax Credit Under the ‎Inflation Reduction Act

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) are steadily churning out guidance on the implementation of the Inflation Reduction Act’s (the “IRA”) expanded tax credits for renewable and...more

That Sinking Feeling: IRS Energy ‎Communities Guidance May Limit Eligibility of Many ‎Offshore ‎Wind Projects

In an ongoing series related to the Inflation Reduction Act (“IRA”), we have been looking at key provisions of the IRA with the potential to benefit the U.S. offshore wind industry. On April 5, 2023, the IRS issued Notice...more

New IRS and Treasury Guidance on ‎Energy Community Bonus ‎Tax Credits Leaves as Many ‎Questions as ‎it Answers

On April 4, 2023, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (“IRS”) published Notice 2023-29, Energy Community Bonus Credit Amounts under the Inflation Reduction Act of 2022 (“the Notice”),...more

Messing with Texas: Texas Legislature ‎Proposes to Establish Permitting ‎Framework for New and ‎Existing Wind and Solar Projects

Texas has long been known for its light-touch regulatory regime, particularly towards the energy industry, but in the current legislative session state lawmakers are considering legislation that would require state permits...more

Generating Debate: D.C. Circuit Affirms ‎That AC Output Determines PURPA Eligibility, ‎While Dissent ‎Decries Chevron Maximalism

On February 14, 2023, a divided D.C. Circuit panel affirmed FERC’s March 2021 ruling that the power output capacity of a generating facility – not the nameplate capacity of its component parts – determines its eligibility as...more

FERC Proposes Rulemaking to Spark ‎Interstate Electric ‎Transmission Development, but Politics May ‎Short-Circuit Proposal

On December 15, 2022, the Federal Energy Regulatory Commission (FERC) issued a Notice of Proposed Rulemaking seeking to revise its regulations governing the siting of interstate electric transmission lines. The NOPR...more

Lek It or Not: ESA Listing of Lesser ‎Prairie-Chicken Has Major ‎Implications for Energy ‎Projects in ‎the Southwest

On November 25, 2022, the U.S. Fish and Wildlife Service (the “Service”) published a final rule listing two Distinct Population Segments (“DPSs”) for the lesser prairie-chicken (Tympanuchus pallidicinctus, “LEPC”) under the...more

Three’s Company: USFWS Proposes ‎Listing Tricolored Bat as Endangered, Joining Indiana and ‎Northern Long-Eared Bats

On September 14, 2022, the U.S. Fish and Wildlife Service (the “Service”) published a proposed rule to list the tricolored bat (Perimyotis subflavus, “TCB”) as endangered under the Endangered Species Act (“ESA”). This action,...more

What the Regulated Community Needs ‎to Know About EPA’s Proposed ‎Designation of PFOA and PFOS ‎as CERCLA Hazardous Substances

On August 26, 2022, the US Environmental Protection Agency (EPA) released a pre-publication version of a highly-anticipated proposal to add two of the most widely-used per- and polyfluoroalkyl substances (PFAS) to the list of...more

Key Climate and Energy Provisions in ‎the Proposed Inflation ‎‎Reduction Act

On July 27, 2022 Senators Joe Manchin (D-WV) and Majority Leader Chuck Schumer (D-NY) reached an agreement to add the Inflation Reduction Act of 2022 (the Act) to the FY 2022 Budget Reconciliation Bill. The Act resurrects...more

EPA Sets Stricter Health Advisory Limits ‎for PFAS – a ‎Harbinger of ‎More Regulation?‎

On June 15, 2022, the U.S. Environmental Protection Agency (EPA) dramatically lowered its lifetime health advisories levels (HALs)[1] for two per- and polyfuoroalkyl substances (PFAS). EPA previously established a combined...more

Not So(lar) Fast My Friends – Uyghur ‎Forced Labor Prevention Act Takes ‎Effect June 21, 2022

The solar industry received welcome news last week when President Biden invoked his emergency authority under Section 318(a) of the Tariff Act of 1930 to mute the impact of the Commerce Department’s anti-circumvention...more

SCOTUS Stays District Court Remand of ‎Trump EPA State Water ‎Quality Certification ‎Rules, Raises ‎Stakes for Upcoming EPA...

On April 6, 2022, the Supreme Court stayed an October 21, 2021 Northern District of California Court ruling that vacated and remanded EPA’s 2020 revisions to the processes for states to certify water quality impacts from...more

Small Bat, Big Implications: USFWS to ‎Uplist Northern Long-Eared Bat From Threatened to ‎Endangered

In today’s Federal Register, the U.S. Fish and Wildlife Service (“USFWS”) published a proposed rule under the federal Endangered Species Act (“ESA”) to reclassify the northern long-eared bat (“NLEB”) from “threatened” status...more

Congress May Not Build Back Better, ‎but DOE Plans to Build a Better Grid

Although President Biden’s “Build Back Better” legislation faces daunting challenges in the Senate, the Administration continues to use the executive branch to push its clean energy agenda forward. Earlier this week, we...more

New York Bight Auction Represents ‎Next Step for Offshore Wind, but Headwinds Remain

On January 12, 2022, the Bureau of Ocean Energy Management (“BOEM”) announced its first ‎offshore-lease auction in over three years. The auction will take place on February 23, and will award ‎leases for over 488,000 acres in...more

Offshore Wind Closes 2021 Strong, ‎Further Growth Expected in 2022

In 2021, the demand for offshore wind in the United States grew significantly. With the recent announcements from Massachusetts and Maryland, over 8,400 MW of offshore wind power was procured last year. This sets a new record...more

A New Season of WOTUS: Court ‎Vacates Trump-Era Navigable Waters Protection Rule

A new season of the regulatory drama “WOTUS” dropped last week. On August 30, a federal court in Arizona granted EPA and the Army Corps of Engineers’ (Corps) (collectively, the “Agencies”) request to remand their 2020...more

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