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Partner Jenny Speck is speaking at the CCUS & Carbon Credits 2025 Conference on December 8 at 2:30 p.m. CT on “What the One Big Beautiful Bill Means for the CCUS Industry.”

On November 20, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”) issued four significant orders addressing crude oil, petroleum products, and natural gas liquids pipelines (collectively, “oil pipelines”) matters: (1) a Notice of Proposed Rulemaking (“NOPR”) for the Five-Year Review of the Oil Pipeline Index (“2026 Index NOPR”) proposing an index level of Producer Price Index for Finished Goods (“PPI-FG”) minus 1.42% for the period (July 1, 2026 to June 30, 2031); (2) an Order denying rehearing and granting oil pipelines remedial relief related to the reinstated oil pipeline index for the period March 1, 2022 to September 17, 2024; (3) an order withdrawing the supplemental notice of proposed rulemaking that proposed to amend the index level to PPI-FG minus 0.21% on a prospective basis from July 1, 2025 until June 30, 2026; and (4) an order denying Airlines for America and the National Propane Gas Association’s petition requesting that the Commission initiate a rulemaking to establish affiliate standards of conduct regulations for oil pipelines.

Stephen Josey and Brie Barry report that recent IRS updates to the fast-track settlement program represent a meaningful move toward more efficient and taxpayer-focused dispute resolution. They note that despite these improvements, additional measures are necessary to reinforce independence and bolster taxpayer confidence.

On November 18, 2025, the U.S. Court of Appeals for the Ninth Circuit ordered a preliminary injunction on the enforcement of SB 261—the California law that requires large companies to publicly disclose their climate-related financial risks in biennial reports.

Vinson & Elkins is a sponsor of the UT Law CLE 2025 Oil, Gas, and Energy Taxation Symposium, taking place Wednesday, November 19 in Houston, Texas.

Partner Jenny Speck is speaking with the Clean Fuels Alliance America (CFAA) Board in Washington, D.C. at 9:15 am on "45Z Transferability."

With the deadline to publish SB 261-compliant climate risk reports rapidly approaching (January 1, 2026), and with legal challenges slowly moving through the court system in the U.S. District Court for the Central District of California and the Ninth Circuit, it perhaps comes as little surprise that industry groups have now sought the emergency involvement of the Supreme Court of the United States (“SCOTUS”).

On November 17, 2025, the Division of Corporation Finance (the “Division”) of the Securities and Exchange Commission (the “SEC”) announced it will not respond to, and will express no views on, requests for exclusions of shareholder proposals brought pursuant to Rule 14a-8 of the Securities Exchange Act of 1934, other than historically relatively uncommon requests relying on Rule 14a-8(i)(1), for the 2025–26 proxy season.

On November 7, 2025, U.S. Environmental Protection Agency (“EPA”) Administrator Lee Zeldin signed a final rule granting Texas primary permitting authority over Class VI Underground Injection Control (“UIC”) permits within the state.

Our panelists discussed recent SEC developments that shape—and the practical considerations that inform—the preparation of public companies’ annual reports and annual shareholder meetings.

Across sectors and jurisdictions, the data point to a world facing more frequent and intense physical disruptions. Extreme heat, heavy rainfall, rising sea levels, and prolonged droughts are no longer regional anomalies; they are macroeconomic factors shaping markets, policy, and investment strategy. The economic toll is mounting: physical damage from extreme weather cost the global economy at least $1.4 trillion last year, according to data compiled by Bloomberg Intelligence.