Regulatory Updates
New York State has imposed a mandatory greenhouse gas emissions reporting program that will require disclosure of 2026 emissions data in 2027. However, unlike California, which applies its mandatory greenhouse gas disclosure regulation to all companies doing business in California, the entities targeted by New York State are much narrower: facilities (i.e., buildings) emitting more than 10,000 tons of CO2 per year, fuel suppliers, electric power entities, and waste haulers (as well as a few other highly specific entities pertaining to waste and agriculture). New York’s regulation thus more closely resembles the one promulgated by Washington State concerning mandatory greenhouse gas emission disclosures, as Washington State likewise focuses on facilities, fuel suppliers, and electric power entities. It is possible that this more narrowly targeted approach to mandatory GHG emissions disclosure, applying only to a relatively limited set of entities, could offer an alternative paradigm should California’s expansive approach be nullified by the federal courts.
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