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REPAIR Act Redux and a New Presidential Memorandum—No End in Sight for NEPA Uncertainty

The National Environmental Policy Act has drawn congressional and presidential frustration for long over a decade and the regulations of the body it created—the Council on Environmental Quality—have often been caught in the...more

New Executive Order on Immediate Measures to Increase American Critical Mineral Production

On March 20, 2025, President Trump signed an Executive Order (“EO”) entitled Immediate Measures to Increase American Mineral Production. The EO builds on previous energy-focused actions taken by the Administration, and...more

President Trump’s Day-One Executive Orders: Energy and Environment

On January 20, 2025, President Trump issued several Executive Orders and memoranda (the “EOs”) signaling a significant policy shift favoring robust and market-based energy production (mostly relying on fossil fuels), while...more

Treasury and IRS Issue Final Regulations Implementing Section 45V Clean Hydrogen Production Tax Credit

On January 3, 2025, the IRS and Treasury issued long-awaited final regulations (the “45V Final Regulations”) implementing the clean hydrogen production tax credit (the “45V Credit”) under Section 45V of the Internal Revenue...more

Guidance on Section 45V Clean Hydrogen Production Tax Credit

The trajectory of the hydrogen sector in the United States hinges on a critical question: what criteria will be used to define the term “clean hydrogen” for tax purposes? As previously outlined in our Field Guide to Clean...more

Beyond the Fenceline: Environmental Justice Updates – December 2023

Environmental Justice: 2023 Year in Review and 2024 Look-Ahead - As a concept, Environmental Justice, or EJ, has been around for more than 40 years. Beginning as a slogan at protests in Warren County, NC in 1982, EJ...more

Field Guide to Clean Hydrogen

Hydrogen is a key ingredient in any country’s future energy plans. In the United States, the hydrogen sector is on the launch pad, ready for lift-off. However, its trajectory hinges on a critical question: what criteria...more

U.S. DOE Releases Report on Clean Hydrogen Strategy and Roadmap

The United States recently took another important step in implementing a comprehensive strategy to advance the production, processing, delivery, storage, and use of clean hydrogen. On June 5, 2023, the Biden-Harris...more

Environmental Justice and Civil Rights in U.S. Construction Projects

Since taking office two years ago, the Biden Administration has emphasized efforts to incorporate environmental justice considerations into federal agency permitting, funding and financial support decision-making....more

Protections for Hydrogen Projects Under the Modernized Energy Charter Treaty

For over two decades, investors in the energy sector have benefited from protections found in The Energy Charter Treaty (“ECT”). Investors in hydrogen projects will soon be able to benefit from these same protections....more

EPA Addresses Environmental Justice and Civil Rights in Permitting

The EPA’s External Rights Compliance Office recently released Interim Environmental Justice and Civil Rights in Permitting Frequently Asked Questions (“the FAQ”). Stressing “that it is time to use the full extent of its...more

Hydrogen-Related Provisions of the Inflation Reduction Act of 2022

The Inflation Reduction Act of 2022, passed by the Senate on August 7, 2022, includes a number of provisions projected to result in significant investments in domestic energy production and manufacturing, and reduce carbon...more

New Railroad Commission of Texas Rules for Natural Gas Infrastructure

Texas regulators recently took additional steps in an effort to prevent another catastrophic loss of power like that experienced during Winter Storm Uri in February 2021. On November 29, 2021, the Railroad Commission of Texas...more

Winter Weather Readiness Requirements for Generation Entities in Texas

With winter coming, many are questioning whether Texas will be able to avoid another catastrophic loss of power like that experienced during Winter Storm Uri in February 2021. While regulators have known the causes of the...more

Bipartisan Senate Infrastructure Bill Promotes Carbon Capture, Utilization, and Sequestration

Few issues in Washington have been as elusive as passage of legislation to address the nation’s aging infrastructure. For a number of years, the White House, Senators and Members of Congress have announced plans to spend...more

EPA, FERC and the Army Corps Weigh in on the Social Costs of Carbon and Environmental Justice in Project Development

Historically, environmental issues have been front and center for major project development throughout the world. But for projects in the United States, the Environmental Protection Agency’s (EPA) increased focus on the...more

Bipartisan Senate Infrastructure Bill Promotes Hydrogen

Few issues in Washington have been as elusive as passage of legislation to address the nation’s aging infrastructure. For a number of years, the White House, Senators and Members of Congress have announced plans to spend...more

FERC Proposes to Amend its PURPA Regulations to Recognize Hydrogen Production in Certain Fuel Cell Systems as Useful Thermal...

Hydrogen as a fuel for industrial applications, transportation, distribution and power generation, and for energy storage, is gaining worldwide momentum as a key component in the pursuit of decarbonization. The Federal...more

Energy Newsletter - June 2020

The Impact of COVID-19 on Nuclear Electricity Sales Contracts in France - The electricity sector, like numerous others in France, has been heavily affected by the economic shutdown due to the COVID-19 pandemic. The...more

FERC Adopts Regulations Delaying Construction of Federally-Regulated Natural Gas Projects Until it Rules on Requests for Rehearing

On June 9, 2020, the Federal Energy Regulatory Commission (FERC) issued a final rulemaking order amending its regulations to preclude the commencement of construction of FERC-authorized natural gas pipeline, storage and...more

Energy Newsletter - March 2020

Disrupting the Disruptor: How a Prepared and Proactive Owner Can Mitigate the Effects of Coronavirus on Construction Projects - Once a remote health issue in China, the rapidly spreading coronavirus (COVID-19) has become...more

PHMSA Issues Final Rule on Underground Natural Gas Storage Safety Establishing a Phased-in, Multi-Year Timeframe for Integrity...

On February 12, 2020, the U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (“PHMSA”) issued its long-awaited Final Rule establishing safety regulations applicable to underground...more

Energy Newsletter - November 2019

The IMO and the Price of Gas or The Impact of the International Maritime Organisation’s Sulphur 2020 Limit for Marine Fuel Oil on the Price of Gas - The main bunker fuel for ships is High Sulphur Fuel Oil (HSFO, with...more

Energy Newsletter - October 2018

Court Faults FERC in its Handling of ANR Storage Company’s Six Year Quest for Authorization to Charge Market-Based Rates for Natural Gas Storage Services - On September 21, 2018, the U.S. Court of Appeals for the District...more

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