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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.

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.

A federal district court in Louisiana has rejected as unlawful President Joe Biden’s withdrawal in early January 2025 of historically large portions of the Outer Continental Shelf (“OCS”) from eligibility for leasing of oil and natural gas.

On October 15, 2025, Louisiana Governor Jeff Landry issued an Executive Order (“Order”) halting the review of all new Class VI Underground Injection Control (“UIC”) well permits in the state and directed the state’s regulator, the Louisiana Department of Conservation and Energy (“LDCE”) to undertake a more careful review of pending Class VI permit applications.

On September 18, 2025, the United States Environmental Protection Agency (“EPA”) published its latest proposed policy in an active year for the Clean Air Act (“CAA”) Renewable Fuel Standard (“RFS”) program.

What can project developers actually build before securing an air permit?

On July 3, 2025, the Federal Energy Regulatory Commission (“FERC” or the “Commission”), the U.S. Army Corps of Engineers (“Army Corps”), and the Departments of Energy (“DOE”), Interior (“DOI”), Transportation (“DOT”), Agriculture (“USDA”), and Defense (“DOD”) released sweeping updates to their regulations and procedures implementing the National Environmental Policy Act (“NEPA”).

On June 17, 2025, the U.S. Environmental Protection Agency (“EPA”) published its proposed “Set 2” rule under the Renewable Fuel Standard (“RFS”) program (the “Set 2 Rule”).

On June 17, 2025, the U.S. Environmental Protection Agency (“EPA”) published a proposed rule that, if finalized, would repeal all greenhouse gas (“GHG”) standards for the power sector.

On June 17, 2025 the U.S. Environmental Protection Agency (“EPA”) published a proposed rule to repeal the amendments to the Mercury and Air Toxics Standards (“MATS”) adopted by the Biden administration in 2024.

In the first major National Environmental Policy Act (“NEPA”) case to reach the Supreme Court in almost two decades, the U.S. Supreme Court issued its decision on May 29, 2025, in Seven County Infrastructure Coalition v. Eagle County, Colorado.

On April 8, 2025, President Trump issued an Executive Order titled “Protecting American Energy From State Overreach” (the “Executive Order”), which directs the United States Attorney General to identify and halt the enforcement of state laws and civil actions that burden energy production and may be preempted by Federal law or are otherwise unconstitutional.