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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 a proposed rule that, if finalized, would repeal all greenhouse gas (“GHG”) standards for the power sector.

The past few years have seen concerted efforts — both domestically and globally — advancing the reporting and disclosure of various climate- and sustainability-related metrics by businesses and investors.

On December 26, 2024, New York Governor Kathy Hochul signed the Climate Change Superfund Act (“CCSA” or the “Act”) into law.

On February 19, 2025, the Council on Environmental Quality (“CEQ”) released a pre-publication version of an interim final rule (the “Interim Rule”) to rescind all of CEQ’s previous and current regulations implementing the National Environmental Policy Act (“NEPA”) alongside a memorandum (the “Memo”) to federal agencies providing guidance on how agencies should revise their individual NEPA regulations and how they should manage NEPA reviews in the meantime.

In his first two days in office, newly inaugurated President Donald J. Trump signed a flurry of Executive Orders, including several aimed at supporting the traditional energy industry.

On December 17, 2024, the Office of Fossil and Carbon Management of the Department of Energy (“DOE”) released the long-awaited Liquefied Natural Gas (“LNG”) Export Study (“Study”). The Study was released 11 months after the Biden administration paused pending decisions to export LNG to non-Free Trade Agreement (“FTA”) countries on January 26, 2024.

The U.S. Environmental Protection Agency (EPA) has finalized a host of new requirements for fossil-fueled power plants, including new source performance standards (“NSPS”) for new and modified coal- and gas-fired plants and emission guidelines for existing coal-fired plants.

This program will highlight what you need to know about how these new rules intersect, new compliance and enforcement risks, and how to plan now for operations and upcoming transactions.

The Environmental Protection Agency (EPA) has published a proposed rule to assess and collect billions of dollars in methane “waste emission charges” from the oil and gas sector.

ExxonMobil (“Exxon”) filed a complaint in the U.S. District Court for the Northern District of Texas on Sunday, January 21, 2024, seeking a declaratory judgment to exclude a shareholder proposal from its proxy statement pursuant to Rule 14a-8 of the Securities Exchange Act of 1934 (“Rule 14a-8”) and not present the proposal for a vote at its 2024 annual shareholder meeting.