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U.S. EPA's New Methane Emissions Charge – My Wallet or Yours?

On January 12, 2024, the EPA announced a proposed new rule entitled Waste Emissions Charge for Petroleum and Natural Gas Systems (the "Proposed Rule"). As required by Congress pursuant to the Inflation Reduction Act ("IRA"),...more

EPA Proposes New Set of Rules to Regulate PFAS Under RCRA

On February 8, 2024, the Environmental Protection Agency ("EPA") proposed two regulations that would add nine per- and polyfluoroalkyl substances ("PFAS") to the list of Resource Conservation and Recovery Act ("RCRA")...more

2023 U.S. Real Estate Round-Up: Effects of State ESG Laws on Commercial and Residential Building Owners

This 2023 U.S. Real Estate Round-Up provides key insights to commercial and residential building owners facing a flock of new state environmental, social, and governance ("ESG") laws proposed or taken effect in 2023,...more

EPA Proposes Regulations to Implement Methane Fee

The U.S. Environmental Protection Agency ("EPA") has proposed regulations for calculating methane emissions fees required beginning this year under the Inflation Reduction Act ("IRA"). Section 136 of the Clean Air Act (added...more

Maryland to Propose Building Energy Performance Standards

The Maryland Department of the Environment ("MDE") will publish proposed rules limiting greenhouse gas ("GHG") emissions from covered buildings and requiring covered building owners to submit detailed energy performance...more

EPA's PFAS Reporting Rule Requires Broad Retroactive Disclosure of PFAS Data

The Situation: In 2019, Congress amended the Toxic Substances Control Act ("TSCA") to require the Environmental Protection Agency ("EPA") to promulgate a reporting rule on per- and polyfluoroalkyl substances ("PFAS"). EPA...more

EPA Finalizes Methane Emission Regulations

The Situation: The Environmental Protection Agency ("EPA") finalized regulations designed to reduce methane emissions from the oil and gas industry by 80% in coming years at both new and existing facilities. The regulations...more

The Climate Report: Fourth Quarter 2023

REGULATORY ISSUES & UPDATES - Mandatory Climate Change Reporting Requirements Under the New European ESRS E1 - The implementation of the European Sustainability Reporting Standards poses risks for reporting companies,...more

Ahead of Methane Emission Fees, EPA Proposes New Reporting Rules for Petroleum and Natural Gas Industry

The Situation: The Inflation Reduction Act ("IRA") requires the U.S Environmental Protection Agency ("EPA") to finalize new greenhouse gas reporting rules for the petroleum and natural gas industry based on "empirical...more

The Climate Report: Third Quarter 2023

REGULATORY ISSUES & UPDATES - New CFTC Enforcement on Carbon Markets Misconduct - The U.S. CFTC publishes a rare alert soliciting tips about potential manipulation in the carbon markets and announces the formation of...more

U.S. Intensifies Environmental Crime Enforcement in Puerto Rico and U.S. Virgin Islands

In Short - The Situation: The U.S. Department of Justice ("DOJ" or "Department") and the U.S. Environmental Protection Agency ("EPA") recently announced the creation of a regional, cross-agency taskforce, targeting...more

The Climate Report | Second Quarter 2023

"Green Day" in the UK - As part of its "Powering Up Britain" strategy, the UK government has published a series of documents setting out its vision for the UK's transition to net zero and the strengthening of UK energy...more

What's Old Is New Again: Anticipating and Defeating Insurer Coverage "Defenses" for Climate Change Litigation

In Short - The Situation: Commercial policyholders are increasingly being targeted by climate change lawsuits alleging that greenhouse gas emissions from their normal operations—and the alleged failure to take...more

Supreme Court Issues Wetlands Ruling in Sackett v. EPA Decision

In Short - The Development: On May 25, 2023, the United States Supreme Court issued its decision inSackett v. EPA, providing new insight into whether wetlands qualify as "waters of the United States" subject to regulation...more

The Agency Strikes Back: EPA Proposes New Emissions Limits for Fossil Fuel-Fired Power Plants

In Short - The Situation: The Environmental Protection Agency ("EPA") has issued proposed rules to limit carbon dioxide ("CO2") emissions from fossil fuel-fired power plants (the "Proposed Rules")....more

California Takes Significant Step Towards Reforming CEQA and Streamlining Infrastructure Projects

On May 19, 2023, California Governor Gavin Newsom unveiled a significant legislative package and signed an executive order aimed at reforming the California Environmental Quality Act ("CEQA") and streamlining infrastructure...more

EPA Proposes TSCA Amendments to Improve Efficiency of New Chemical Review Process

The proposal would also make per- and polyfluoroalkyl substances ("PFAS") and certain persistent, bioaccumulative, and toxic chemical substances ("PBTs") ineligible for exemptions available under the Toxic Substances Control...more

EPA Proposes New Carbon Pollution Standards for Fossil Fuel-Fired Power Plants

The Environmental Protection Agency ("EPA") is proposing stringent carbon dioxide emissions standards for coal- and gas-fired power plants....more

EPA is Seeking Comment on Potential Designations of Additional PFAS as Hazardous Substances Under CERCLA

The Advance Notice of Proposed Rulemaking ("ANPRM") addresses seven per- and polyfluoroalkyl substances ("PFAS"), including PFBS and GenX. ...more

Bureau of Land Management Publishes Proposed Rule That May Redefine the Management of Public Lands

The Bureau of Land Management ("BLM") announced a sweeping proposed rule that would change how public lands are managed by the federal government. On April 3, 2023, BLM published a proposed rule to promote the...more

EPA Proposes Stricter Mercury and Air Toxics Standards for Power Plants

The Environmental Protection Agency ("EPA") has announced a new proposed rule that would strengthen the National Emission Standards for Hazardous Air Pollutants ("NESHAP") for Coal- and Oil- Fired Electric Utility Steam...more

New York Proposes Exemption From Bar to Contribution Claims for PFAS Cleanup

The proposed amendment to NY law establishes a right to contribution for cost-recovery claims for settling parties in tort actions who clean up PFAS contamination. Per- and polyfluoroalkyl substances ("PFAS") are synthetic...more

EPA Proposes Standards to Limit Certain PFAS Substances in Drinking Water

On March 14, 2023, the EPA took a step toward imposing federal limits on certain per- and polyfluoroalkyl substances in drinking water under the Safe Drinking Water Act. The United States Environmental Protection Agency...more

The Climate Report | First Quarter 2023

Incoming: Mandatory Climate Risk Disclosures in Australia - The Climate-Related Financial Disclosure Consultation Paper proposes that, commencing with the 2024/2025 financial year, large, listed entities and large...more

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

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