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D.C. Circuit Forces EPA to Confront Reality of Economic Impacts of RFS on Small Refiners

On August 14, 2024, the United States Court of Appeals for the District of Columbia Circuit (“D.C. Circuit”) released a redacted copy of its opinion in Sinclair Wyoming Refining Co. LLC v. EPA, in which the D.C. Circuit...more

Appeals Court Invalidates Key Parts of PHMSA’s 2022 Rulemaking on Natural Gas Safety

In a unanimous opinion, a panel of judges from the United States Court of Appeals for the District of Columbia Circuit (the “D.C. Circuit”) vacated four key aspects from a 2022 rulemaking by the Pipeline and Hazardous...more

EPA Finalizes Revisions to Risk Management Program (RMP) Regulations, with Special Focus on Petroleum and Chemical Manufacturers

The U.S. Environmental Protection Agency (EPA) has issued a final rule (the “Rule”) that substantially expands its Risk Management Program (“RMP”) regulations aimed at preventing chemical accidents. The Rule takes effect on...more

BOEM Releases Tougher Financial Assurance Requirements for Offshore Oil and Gas Operations

New and additional bonding requirements for certain companies operating on the Outer Continental Shelf (“OCS”) will take effect in June as a result of a recent rulemaking. These new requirements will be phased in over a...more

The EPA’s Methane Waste Emission Charge: A Tax by Any Other Name

The Environmental Protection Agency (EPA) has published a proposed rule to assess and collect billions of dollars in methane “waste emission charges” from the oil and gas sector....more

BOEM Bonding: What You Need to Know About New Financial Assurance Requirements Proposed for Offshore Oil and Gas Drilling

The Biden administration has proposed changes regarding when oil, gas, and sulfur lessees and certain other parties operating in the offshore Outer Continental Shelf must post additional bonds or other “supplemental financial...more

EPA Finalizes RFS Set Rule and Biogas Regulatory Reforms, But Drops eRins (For Now)

The U.S. Environmental Protection Agency (“EPA” or “the Agency”) this week released its final Renewable Fuel Standard (“RFS”) “Set Rule”.1 As explained in our prior article, the Set Rule represents a new period for the RFS,...more

New York’s Climate Action Plan

In an ambitious step toward New York state’s climate goals, the New York State Climate Action Council approved a Scoping Plan on December 19, 2022, which sets forth a series of recommended policies and actions. The 445-page...more

The Carbon Border Adjustment Mechanism (“CBAM”) – the European Union’s Next Climate Action Step

As a result of ongoing discussions, the European Parliament and the Council of the European Union announced on December 13, 2022, that a provisional agreement had been reached to implement a European Union (“EU”) Carbon...more

Renewable Fuel Standard: The Next Generation

Long awaited, the U.S. Environmental Protection Agency (“EPA”) last week released the proposed Renewable Fuel Standard (“RFS”) “set” rule. The set rule represents a new era for EPA in setting biofuel targets, as the targets...more

PHMSA’s Mega Rule Is Complete: Here’s What You Should Know

The Pipeline and Hazardous Materials Safety Administration (“PHMSA”) recently released the final rule in a rulemaking trilogy collectively known as the “Mega Rule” — a set of regulations designed to improve pipeline safety by...more

EPA Issues Broad Updates to Renewable Fuel Standards Program: 5 Things to Know

The Environmental Protection Agency (“EPA”) has recently finalized volumes for compliance years 2020, 2021, and 2022 under the Clean Air Act (“CAA”)’s renewable fuel standard (“RFS”) program and took several other related...more

PHMSA Suggests Operators Should Be Prepared to Operate Sophisticated Pipelines Manually

Should hazardous liquids pipelines be prepared to operate “manually” in the event of a future cyberattack? An almost million dollar fine proposed by the Pipeline and Hazardous Materials Safety Administration (“PHMSA”) on...more

EPA Releases New Proposed Rule for Clean Water Act Hazardous Substance Worst Case Discharge Planning

What You Need to Know- EPA has just released a proposed rule that would require facilities near “navigable water” that store listed hazardous substances above a threshold amount to prepare facility response plans for...more

DHS Pipes Up Again: Issues Second Directive On Pipeline Security

On July 20, 2021, the Department of Homeland Security’s Transportation Security Administration (“TSA”) announced the issuance of a second Security Directive regarding further enhancements to pipeline cybersecurity (the “July...more

United States Becomes Chair Of The Biofuture Platform Initiative

In June 2021, the United States (“U.S.”) became the chair of the Biofuture Platform Initiative, an initiative of the Clean Energy Ministerial (the “Biofuture Platform”) for a two-year term, taking over the chair position from...more

Not Dead (Yet?): After HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Association, The Renewable Fuels Standard’s...

In its June 25, 2021 decision in HollyFrontier Cheyenne Refining, LLC v. Renewable Fuels Association, the Supreme Court rejected the central holding of a January 2020 decision by the U.S. Court of Appeals for the Tenth...more

Washington State’s Climate Change Fight: Clean Fuels Standards And Cap-And-Trade Program

Washington recently joined California, Oregon, and British Columbia in adopting a clean fuels standard that mandates reductions in greenhouse gas (“GHG”) emissions attributable to transportation fuels. In the final days...more

DHS Pipes Up: Issues Directive On Enhancing Pipeline Cybersecurity

On May 27, 2021, against the backdrop of the Colonial Pipeline cybersecurity incident, the Department of Homeland Security’s Transportation Security Administration (“TSA”) announced Security Directive Pipeline-2021-01...more

Transportation Climate Initiative May Have Significant Impacts On Fossil Fuels Commodity Contracts In The Northeast USA

Beginning in 2023, sellers and owners of fossil fuels for use in transportation markets in three states and the District of Columbia may need to purchase allowances for sales in those jurisdictions based on a recent agreement...more

The PIPES Act Of 2020: What Regulated Entities Need To Know

Congress recently passed legislation with a reauthorization of the pipeline safety programs through 2023 as a part of the Consolidated Appropriations Act. The Protecting Our Infrastructure of Pipelines and Enhancing Safety...more

Biden Administration Halts New Oil And Gas Leasing On Federal Public Lands: What You Need to Know

On January 27, 2021, President Biden issued an executive order — effective immediately — directing the Secretary of the Interior to pause new oil and natural gas leases on federal public lands or offshore waters to the extent...more

SEC Alters Long-Standing Monetary Sanctions Threshold For Disclosing Environmental Proceedings: Hybrid Approach Adopted

On August 26, 2020, the U.S. Securities and Exchange Commission (“SEC”) issued a final rule amending Regulation S-K that, among other things, changes a long-standing test obligating registrants to disclose certain...more

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