On October 20, 2025, a coalition of nineteen leading companies in the energy, finance, and logistics sectors, launched the Carbon Measures Coalition, proposing a significant departure from established carbon accounting frameworks. The Coalition represents a prominent industry-led effort to move away from traditional inventory-based emission calculation methods toward a
Continue Reading Carbon Measures Coalition Signals Growing Momentum for Ledger-Based Carbon AccountingEva Dorrough
Eva Dorrough is an associate in the firm’s San Francisco office. She is a member of the Environmental and Energy Practice Group, advising clients on state and federal environmental regulations, enforcement actions, and climate disclosure laws. She also works on complex litigation matters in the Commercial Litigation Practice Group and maintains an active pro bono practice.
The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for Stakeholders
By Kevin Poloncarz, W. Andrew Jack, Jayni Hein, Paul Mertenskötter, Eva Dorrough & Elise Hartnett on
Posted in Carbon Markets, Policy, and Management
In late October, the Greenhouse Gas Protocol (“GHG Protocol”) proposed updated Scope 2 guidance for companies quantifying and reporting their greenhouse gas (“GHG”) emissions. If finalized as proposed, the guidance would have significant impacts on how companies plan their renewable energy investments and measure progress toward their climate goals. The…
Continue Reading The Greenhouse Gas Protocol’s Proposed Scope 2 Guidance: Key Changes and Considerations for StakeholdersState Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing Program
By Jayni Hein, Paul Mertenskötter & Eva Dorrough on
Posted in Disclosure Requirements
While the Environmental Protection Agency (“EPA”) is proposing to amend the federal Greenhouse Gas Reporting Program (“GHGRP”) to remove reporting requirements for nearly all sources, it remains important for companies to track developments and manage their compliance obligations with existing and emerging state GHG reporting programs. Several states, such as…
Continue Reading State Greenhouse Gas Reporting Programs: New York’s Proposed Mandatory Reporting Program and California’s Existing ProgramWill the Trump Administration Clear a Path through the FERC Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 2 of 2)
By Mark Perlis, Eva Dorrough & Jayni Hein on
Posted in Nuclear
The exploding demand for energy to power hyperscaler data centers is leading to consideration of co-locating new generation (nuclear or otherwise) and data centers. As we explained in Part 1 of this blog, co-location is attractive to hyperscalers because of its potential to provide those data centers with contractually…
Continue Reading Will the Trump Administration Clear a Path through the FERC Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 2 of 2)Will the Trump Administration Clear a Path through the Nuclear Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 1 of 2)
By Mark Perlis, Eva Dorrough & Jayni Hein on
Posted in Nuclear
During his first week in office, President Trump issued Executive Orders on Removing Barriers to American Leadership in Artificial Intelligence, Declaring a National Energy Emergency, and Unleashing American Energy. On February 14, he issued another Executive Order, Establishing the National Energy Dominance Council. He has also…
Continue Reading Will the Trump Administration Clear a Path through the Nuclear Regulatory Thicket for the Co-Location of Data Centers with Nuclear Generation? (Part 1 of 2)California Air Resources Board Solicits Stakeholder Feedback on Implementation of Climate Disclosure Laws on the Heels of New Enforcement Advisory
By Kevin Poloncarz, Jayni Hein & Eva Dorrough on
On Monday, December 16, the California Air Resources Board (CARB) issued an information solicitation inviting feedback on the implementation of SB 253 and SB 261. Comments are due by February 14, 2025. This information request arrives on the heels of a new CARB enforcement advisory focused on SB 253. Continue Reading California Air Resources Board Solicits Stakeholder Feedback on Implementation of Climate Disclosure Laws on the Heels of New Enforcement Advisory