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.
For energy companies, developers, and investors, success in 2026 will depend not only on understanding the rules, but on strategically navigating a rapidly changing regulatory landscape.
The global race for critical minerals is no longer a future prospect; it is a current economic and national security imperative. The surge in demand for rare earth metals, essential for everything from electric vehicle batteries to defense technologies, has propelled a specialized niche in the legal sector.
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.
