Federal rules in flux
At the federal level, EPA has repealed its greenhouse gas standards for vehicles and most of those for power plants and has proposed further cuts, and several of those actions have been challenged in court. EPA has also rescinded the finding that underpinned federal vehicle climate rules, a step that has drawn its own legal challenges. The SEC's climate disclosure rule did not take effect as planned, and the agency stopped defending it. Some federal emissions reporting obligations for large emitters have also been the subject of rollback proposals. Because these rules are changing or in litigation, any compliance plan built on federal requirements needs a current check rather than reliance on what applied a short time ago.
State, city, and foreign requirements
Other rules continue to move regardless of Washington. New York State has climate legislation that sets long-term emission targets and has been developing reporting and pricing programs to support them, with timing that has shifted. In New York City, Local Law 97 sets emissions limits for many large buildings, with penalties for exceeding them, and owners have been working through compliance plans and alternative pathways. California has adopted corporate climate disclosure laws that reach companies doing business there, parts of which have been challenged in court. Companies shipping certain goods into the European Union are affected by its carbon border mechanism, under which importers account for the emissions embedded in those goods and often ask suppliers for the data.
Building a compliance picture
We start by mapping which rules actually reach the business: the buildings and facilities it owns or leases, the states where it operates, its customers' contractual demands, and its exports. Leases deserve attention because they often decide whether the owner or the tenant bears the cost of building emissions requirements. Public statements about emissions or climate commitments should be reviewed for accuracy, since overstated environmental claims can draw consumer protection or securities scrutiny. Bring the emissions data you have, energy bills, leases, and any customer or regulator requests to a first conversation.
