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EPA and Army Corps Promulgate New Expansive Definition of Waters of the United States

In Short - The Situation: In 2021, the Biden Administration signaled its intent to replace the 2020 "Navigable Waters Protection Rule," which was vacated by a federal court, with a new definition of "waters of the United...more

EPA Proposes Tougher Air Quality Standards for Soot Pollution

The Environmental Protection Agency ("EPA") has announced a proposal to reduce the maximum levels of fine particle emissions....more

Decarbonizing for Net Zero

Determining progress toward achieving carbon neutrality or "net zero" can be difficult. One complicating factor is existing and proposed carbon accounting metrics that use different "scopes" to count direct and indirect...more

Inflation Reduction Act of 2022: Energy Security and Climate Change Programs

Snapshot of Incentives - Consumer incentives include tax credits for clean and efficient energy, $9 billion in home energy rebate programs, a $4,000-$7,500 tax credit for qualified individuals to purchase zero-emission...more

The Climate Report | Third Quarter 2022

REGULATORY ISSUES & UPDATES - European Taxonomy Regulation Extended to Natural Gas and Nuclear Energy - The regulation is likely to create new opportunities for natural gas and nuclear energy in the European Union,...more

U.S. Supreme Court Limits How EPA Can Regulate Greenhouse Gases

In West Virginia v. EPA, a case argued by Jones Day, the U.S. Supreme Court determined that Congress did not authorize the U.S. Environmental Protection Agency ("EPA") to compel generation shifting among existing electric...more

U.S. Supreme Court Curbs Executive Power and Reach of EPA

What Happened: West Virginia v. EPA - In West Virginia v. EPA, the Supreme Court ruled in favor of Jones Day client, the North American Coal Corporation, and determined that the EPA did not have clear authorization from...more

EPA Proposes Methane Emission Regulation for Existing Oil and Gas Production

After years of attempts with varying success to regulate methane emissions from new oil and gas wells, the Biden administration has shifted strategy in proposing a regulatory program covering both new and existing oil and...more

Climate Change Diligence—An Emerging Focus in U.S. Transactions

In transactions, climate change diligence is generally directed at examining the climate change impact of a potential investment. This involves focusing both on confirming the information provided by the target of the...more

FERC Announces Greenhouse Gas Emissions Will Be Considered in Review of Natural Gas Pipeline Certificates

On March 22, 2021, the U.S. Federal Energy Regulatory Commission ("FERC") issued an order authorizing Northern Natural Gas Company ("Northern") to abandon-in-place a segment of its natural gas pipeline running from Nebraska...more

Temporary Ban on New Federal Oil and Gas Leases Under Fire

First Quarter of Biden Presidency Impactful for Energy Industry - On January 27, 2021, President Biden signed Executive Order 14008 ("E.O. 14008"), implementing a temporary pause on the auction of new oil and gas leases...more

Interim Update on Biden Administration Climate Change Initiatives

Interim Update on Biden Administration Climate Change Initiatives - The last edition of the Climate Report discussed President Biden's signing, on his first day in office, of an instrument for the United States to re-join...more

The Climate Report | Second Quarter 2021

Climate Change Regulatory Issues & Updates - Interim Update on Biden Administration Climate Change Initiatives - The last edition of the Climate Report discussed President Biden's signing, on his first day in office,...more

Biden Administration Announces Moratorium on New Federal Oil and Gas Leases

The Biden administration's Executive Order on Tackling the Climate Crisis at Home and Abroad ("Executive Order") expands upon the Department of the Interior's Secretarial Order No. 3395 and indefinitely suspends the federal...more

Supreme Court Rules Some Discharges to Groundwater Require Clean Water Act Permits

The Situation: The Supreme Court held that a discharge through groundwater that is the functional equivalent of a direct discharge to navigable waters requires a Clean Water Act permit. The Result: Some discharges to...more

The Climate Report | Summer 2019

Climate Change Regulatory Issues & Updates - EPA Issues Affordable Clean Energy Rule - The U.S. Environmental Protection Agency ("EPA") issued the Affordable Clean Energy rule on July 8 to repeal the Clean Power Plan...more

Is Fossil Fuel Running on Empty? The Implications of Climate Change Mitigation

The Situation: Proposed resolutions in Congress and an injunction request in a Ninth Circuit case both seek significant reductions in fossil fuel use throughout the economy. The Result: In the near term, it is easy to...more

Proposed Waters of the United States Rule Narrows Federal Clean Water Act Jurisdiction

February 2019 In Short The Situation: The definition of "waters of the United States" in the Clean Water Act ("CWA") circumscribes the jurisdictional authority of the federal government under the Act. This impacts not just...more

EPA Offers ACE Rule to Trump Clean Power Plan

Outlined in an Environmental Protection Agency ("EPA") proposal published on August 31, 2018, the Affordable Clean Energy ("ACE") rule would replace the Obama Administration's Clean Power Plan ("CPP"). A 60-day public comment...more

EPA Memo Signals Plant Improvement Opportunities

A policy memorandum issued by the U.S. Environmental Protection Agency (“EPA”) during December 2017 clarifies how the agency will apply and enforce certain facets of the New Source Review regulations following a pair of...more

The Climate Report - Fall 2017

US. REGULATORY AND LITIGATION DEVELOPMENTS - EPA PROPOSES TO RESCIND CLEAN POWER PLAN - What EPA Did - In a decision expected and promised since the election of President Donald Trump, the United States...more

No Accord: Summarizing the U.S. Withdrawal from the Paris Climate Agreement

On June 1, 2017, President Trump announced that the "United States will cease all implementation" of the Paris Climate Accord. This Commentary provides a short summary of the impacts of President Trump's announcement....more

Two Bureau of Land Management Regulations on Life Support Under President Trump

The Trump Administration has signaled its intent to pull the plug on two rules issued by the U.S. Department of Interior's Bureau of Land Management ("BLM") in 2015 and 2016. Legal and legislative developments over the next...more

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