New York is Latest State to Finalize Greenhouse Gas Reporting Rules for 2026
The New York State Department of Environmental Conservation (NYDEC) finalized its long-awaited Mandatory Greenhouse Gas (GHG) Reporting Program (Part 253), which implements GHG reporting requirements for businesses in New York consistent with directives under the 2019 Climate Leadership and Community Protection Act (CLCPA) and aids the State in meeting obligations under the northeast Regional Greenhouse Gas Initiative (RGGI). The final rule is, in part, the result of an October 2025 court order that required NYDEC to promulgate regulations addressing climate change after NYDEC initially failed to issue the regulations by the CLCPA deadline. Part 253, as finalized, largely conforms with the draft regulations NYDEC proposed in 2025 but includes revisions to address some of the concerns raised by industry stakeholders. New York becomes the fourth state to implement a GHG reporting program after California, Washington, and Oregon.
California Environmental Law Update: Key Legislative and Regulatory Updates To Track in 2026
California enacted a wide-ranging slate of environmental and climate legislation in 2025 and in prior years, with many of the resulting requirements taking effect in 2026 that will impact companies operating in or doing business with the state. These developments span climate disclosure and financial reporting, greenhouse gas regulation, energy and fuel markets, California Environmental Quality Act (CEQA) reform, and public health and safety standards. The below roundup highlights a collection of key new statutes and regulatory changes that the industry should be tracking now to assess compliance obligations and strategic planning considerations heading into 2026 and future years.
Council on Environmental Quality Issues Long Awaited Guidance for Environmental Review Across Agencies
On September 29, 2025, the Council on Environmental Quality (CEQ) issued long-awaited guidance to formalize agencies’ individual efforts to implement the National Environmental Policy Act (NEPA). After rescinding the CEQ regulations that shaped NEPA for 40+ years and bearing witness to various agencies’ independent efforts to issue their own NEPA rules, CEQ issued new guidance to more systematically guide the agencies’ efforts. As CEQ notes, “NEPA implementation reform now has been called for, authorized, and directed by all three branches of government at the highest possible level: Congress, the President, and the Supreme Court.” The guidance reflects direction from each.
D.C. Circuit Upholds U.S. EPA’s HFC Cap-and-Trade Program Under AIM Act
On August 1, 2025, the U.S. Court of Appeals for the D.C. Circuit upheld the U.S. Environmental Protection Agency’s (EPA) authority under the American Innovation and Manufacturing (AIM) Act to phase down hydrofluorocarbons (HFCs) through a cap-and-trade program. In IGas Holdings, Inc. v. EPA, No. 23-1261, a unanimous panel rejected constitutional and administrative law challenges from refrigerant industry members, finding that the AIM Act provides a clear “intelligible principle” to guide EPA’s allowance allocation. The Court also held that EPA’s decision to exclude 2020 market data from its allocation methodology was not arbitrary and capricious.
H.R.1: What You Should Know About the Environmental and Energy Provisions in the “One Big Beautiful Bill” Act
On July 4, President Trump signed H.R.1—the “One Big Beautiful Bill,” referred to as the OBBB—into law. This sweeping tax and policy law, enacted through the process of budget reconciliation requiring a simple majority vote by Congress, carries significant implications for environmental funding, clean energy development, and climate-related programs administered by the U.S. Environmental Protection Agency (EPA), as well as the tax code. Much of the provisions affect programs and funding originally authorized under the 2022 Inflation Reduction Act (“IRA”), which was former President Biden’s signature budget reconciliation bill. Below, we outline some of the key features of the OBBB environmental and energy provisions.
Congress Eliminates Corporate Average Fuel Economy (CAFE) Penalties for Passenger Cars and Light Trucks
In one of its many changes, the One Big Beautiful Bill Act, enacted on July 4, 2025, eliminated civil penalties for noncompliance with federal fuel economy standards. Specifically, Section 40006 of the Act amends the language of the Corporate Average Fuel Economy (CAFE) statute to reset the maximum civil penalty to $0.00. Although the statute and its implementing regulations otherwise remain in place, this amendment removes any civil penalties for producing passenger cars and light trucks that do not meet fuel economy requirements.
New York Proposes Mandatory Greenhouse Gas Reporting Rule
Last month, the New York State Department of Environmental Conservation (DEC) announced that it is considering a rule that would subject certain greenhouse gas (GHG) emissions sources to a mandatory reporting rule. This proposed rule aims to collect comprehensive emissions data from large GHG emitters across the state. Although the rule only proposes to impose reporting requirements, DEC has announced plans to use the information obtained to develop further strategies to reduce GHG emissions and direct investments to renewable energy alternatives.
The Future of Environmental Review of Federal Permitting Remains Unsteady as White House Seeks to Rescind NEPA Regulations
On February 19, 2025, the Council on Environmental Quality (CEQ) submitted a proposed Interim Final Rule rescinding its regulations implementing the National Environmental Policy Act (NEPA). The Rule will become effective 45 days after its publication in the Federal Register, marking the end of nearly 50 years of CEQ regulations serving as the foundation for federal environmental reviews. This Interim Rule comes right at the deadline set by President Trump’s Executive Order (EO) 14154—Unleashing American Energy—which rescinded CEQ’s authority to issue NEPA regulations and revoked President Carter’s EO 11991, which had originally directed CEQ to promulgate implementing regulations.
Top 5 Energy Actions You Should Know from President Trump’s First Day
On January 20, 2025, President Trump began his second term with the signing of 26 executive orders (EOs), which included the recission of almost 80 EOs of the previous administration. Trump’s orders contain both repeals of key Biden Administration policies and calls to agency action to reassess treatment of major energy issues associated with domestic energy production. Here are the top five actions to know from President Trump’s first day as the new administration begins its reshaping of U.S. energy policy for his second term in office.
Federal Government Withdraws Proposed Climate Disclosure Requirements for Federal Contractors
On January 13, 2025, the federal government withdrew a proposed rule that would have required government contractors to publicly disclose their greenhouse gas (GHG) emissions and set emissions reduction goals. The withdrawal comes on the eve of the transition to the second Trump administration, which is expected to take a very different approach to climate regulation and disclosure than has been advanced during the Biden administration.
