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NEPA Modernization Promises Significant Change

Agency consideration of climate change curtailed in update to decades-old policy - On January 9, 2020, President Trump’s Council on Environmental Quality (“CEQ”) proposed to “update” the nearly forty-year-old regulations...more

U.S. Government’s Continued Focus on Large Ship Air Emissions

The U.S. Environmental Protection Agency (“EPA”) and the U.S. Coast Guard (“USCG”) continue to signal interest in addressing air pollution from large ships and ocean-going vessels. Since statements made by EPA personnel in...more

Energy Newsletter - December 2019

Rekindling the Flame: Oil & Gas Securitizations - A number of recent structurings of investment-grade rated securitizations of oil and gas wells are sparking conversations in the U.S. upstream oil and gas industry about...more

Fifth Circuit Extends Doiron Test For Assigning Maritime-Contract Status To Contracts That Are Not Oilfield Services Contracts

The U.S. Court of Appeals for the Fifth Circuit recently held that its two-question Doiron test for determining whether oilfield services contracts are maritime contracts also applies when evaluating the maritime-contract...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

Taking Cues from Justice Department, New Executive Orders Limit Agency Use of Guidance to Establish and Enforce Regulatory Policy

On October 9, 2019, President Trump signed two executive orders: Promoting the Rule of Law Through Improved Agency Guidance (Executive Order 13891) (the “Guidance Executive Order”) and Promoting the Rule of Law Through...more

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