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Major Investment Manager Makes Climate-Related Disclosure a Priority for 2017-2018

Earlier this month the world’s largest asset manager, BlackRock, Inc., announced five “engagement priorities” for the coming year. Improving climate risk disclosure made BlackRock’s priority list alongside the more traditional areas of focus: governance, corporate strategy, compensation and human capital. BlackRock stated it will “engage companies most exposed to climate risk to understand their views on the TCFD [Task Force on Climate-related Financial Disclosures] recommendations and to encourage them to consider using this reporting framework as it is finalized and subsequently evolves over time.”

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  • 14
  • March
  • 2017

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EPA Withdraws Request for Information About GHG Emissions From the Oil and Gas Industry

On March 2, 2017, EPA announced that it was withdrawing its information collect request (the “ICR”) asking owners and operators in the oil and natural gas industry to provide information on equipment and air emissions at existing oil and gas operations. The withdrawal is effective immediately, meaning owners and operators—including those who have received an extension to their due dates for providing the information—are no longer required to respond to the request. Unlike other actions taken by the prior administration’s EPA, such as final regulations promulgated in compliance with the Administrative Procedure Act (“APA”), the ICR could be withdrawn without notice and comment, because it was not a rule subject to APA procedures.

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  • 17
  • February
  • 2017

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Beyond Regulations: What Additional Changes to Climate Change Policy Could Happen Under the Trump Administration?

The few public statements from then-candidate Trump regarding climate policy indicated that he will seek to reverse much of his predecessor’s course on laws and policies pursued in the name of preventing climate change, including the Paris Agreement and the Clean Power Plan. The President has also stated that he wants to cut regulations by 75%, and released an Executive Order limiting the creation of new regulations. But even outside of the realm of formal regulations, there are a number of climate-related policies of the previous administration that could be impacted by President Trump’s policy preferences.

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With the Clean Power Plan Under Attack Could a Climate NAAQS be Next?

While on the campaign trail, President Trump made several statements suggesting that he will seek to reverse many of the regulations and guidance documents that constitute President Obama’s Climate Action Plan, including the Clean Power Plan. Recent actions and statements by the Trump Administration have further signaled the potential for a significant reversal of U.S. climate policy. Given that the new Administration is unlikely to pursue further policies aimed at cutting greenhouse gas (GHG) emissions, and may even attempt to roll back some existing regulations, many environmental organizations and think tanks are considering alternative measures to achieve emission reductions.

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  • 21
  • September
  • 2016

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North Dakota Reveals Basic Framework for Challenge of EPA's Quad Oa Methane Regulations for the Oil and Gas Sector

As discussed in this previous post, a number of states and industry groups have taken a stand against the Environmental Protection Agency’s new methane and VOC emissions regulations for the oil and gas sector (“Quad Oa”). North Dakota recently provided additional insight about the claims that it plans to bring against EPA in the U.S. Court of Appeals for the D.C. Circuit.

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Texas Challenges EPA’s Failure to Make New Endangerment Findings for the Quad Oa Methane Rules for the Oil and Gas Sector

As discussed in this previous post, a number of states and industry groups have challenged EPA’s new VOC and methane emission regulations for the oil and gas sector (“Quad Oa”). Texas has now further defined the claims it plans to bring against EPA in the U.S. Court of Appeals for the D.C. Circuit.

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Margaret E. Peloso

Margaret E. Peloso Counsel

Eric Groten

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