The EPA has extended the 2025 Greenhouse Gas Reporting Program deadline to March 10, 2027, while considering proposed changes that could significantly reduce or eliminate reporting requirements for certain industries. Companies should continue preparing for compliance as the program’s future remains uncertain.
An OCC no-further-action letter and a final order closing a spill site do not bind a district court hearing a private nuisance claim. But the court may weigh them as evidence and may rely on them in holding that a plaintiff has not shown (by clear and convincing evidence) the likelihood of success needed to justify a mandatory cleanup injunction.
Although EPA has proposed eliminating most GHGRP source categories and suspending reporting obligations for much of the oil and gas sector, those proposals have not been finalized. Accordingly, facilities currently subject to GHGRP reporting should continue to treat existing reporting obligations as fully enforceable unless and until EPA takes final regulatory action.
Despite two years of political and regulatory turbulence, the Environmental Protection Agency’s (“EPA”) New Source Performance Standards (“NSPS”) Subparts OOOOb/c remain in effect and are the dominant framework for regulating methane and volatile organic compound (“VOC”) emissions in parts of the oil and gas sector.
The Department of Justice has renamed its Environment and Natural Resources Division (ENRD) the Energy and Natural Resources Division. The rename is not just a branding exercise. It aligns DOJ’s environmental and natural resources litigation shop with the Administration’s broader energy program.
On December 5, 2025, EPA Assistant Administrator Craig Pritzlaff issued a memorandum directing the Office of Enforcement and Compliance Assurance to adopt a renewed “compliance first” approach across all civil enforcement and compliance programs.
In this edition of GableGotwals’ PFAS Pulse, we track the latest developments in per- and polyfluoroalkyl substances (“PFAS”) regulation and litigation. As the PFAS regulatory landscape tightens in some areas and recalibrates in others, companies across the supply chain should treat PFAS compliance as an ongoing priority.
Environmental issues surface in far too many deals only after the business terms are locked in, diligence windows are closing, lenders start asking hard questions, and after the opportunity to meaningfully and more accurately allocate risk has slipped away.
