On March 23, 2026, the California Air Resources Board (CARB) held a public workshop initiating the next phase of rulemaking under SB 253, California’s Climate Corporate Data Accountability Act. CARB presented preliminary, pre‑rulemaking concepts that would govern greenhouse gas (GHG) emissions reporting beginning in 2027. Because the first reporting year would cover 2026 emissions, potentially regulated entities should consider evaluating these concepts now and may wish to submit comments to CARB’s rulemaking docket before April 13, 2026.

Click here to read the full GT Alert.

Photo of Myles Culhane Myles Culhane

Myles Culhane is an energy and environmental lawyer with deep experience across the evolving energy transition. With both legal experience and engineering expertise, he translates complex technical systems into practical regulatory and transactional strategies to help clients manage long‑term liability, secure financing, meet…

Myles Culhane is an energy and environmental lawyer with deep experience across the evolving energy transition. With both legal experience and engineering expertise, he translates complex technical systems into practical regulatory and transactional strategies to help clients manage long‑term liability, secure financing, meet compliance obligations and advance stakeholder support.

During his tenure as Occidental Petroleum’s (Oxy) senior climate, environmental, sustainability and regulatory practice, Myles advised on major multi-party transactions, expansion of anthropogenic carbon dioxide use in enhanced oil recovery (CO2-EOR), and strategies to maintain eligibility for federal 45Q tax credits. He has significant experience addressing novel legal issues related to UIC Class VI CO2 injection permitting and supported the development, authorization, and verification of the first commercial scale direct air capture (DAC) facility.

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Photo of Thomas R. Brill Thomas R. Brill

Thomas R. Brill has deep legal and management experience in the energy industry and has represented clients in virtually every electricity and natural gas restructuring proceeding in California for over three decades. Tom also has comprehensive experience in regulatory litigation, as well as…

Thomas R. Brill has deep legal and management experience in the energy industry and has represented clients in virtually every electricity and natural gas restructuring proceeding in California for over three decades. Tom also has comprehensive experience in regulatory litigation, as well as strategy and policy development to address rapidly changing laws, regulations, and market dynamics as well as technological disruptions that are leading to significant changes in the energy industry. Tom also has comprehensive experience addressing issues related to the integration of central station and distributed renewable generation, including electricity storage, smart grid technologies, and the impacts of utility rate design and cost allocation on competitive entry by third party providers and utility stranded cost exposure.

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Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice

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Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including private and public financings, dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. She serves as a trusted advisor to public and private company boards of directors on governance matters and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and public and private companies in emerging technology, life sciences and biotechnology, defense and security, blockchain and digital assets, telecommunications, information technology, energy (traditional and renewable), mining, media, entertainment and sports. Barbara also represents Olympic and professional athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 1997 with Sullivan & Cromwell, LLP, and headed the international capital markets practice of Kirkland & Ellis LLP from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters, strategic alternatives, and digital asset structures. She serves on the Government of Bermuda’s Global FinTech Advisory Board.

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Photo of Alice Kessler Alice Kessler

Alice Kessler is the Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office. She is an accomplished legislative strategist and leader with a track record of rapid advancement grounded in proven strategic and communication talents, collaborative skills, and…

Alice Kessler is the Co-Leader of the California Government Law & Policy Group in the firm’s Sacramento office. She is an accomplished legislative strategist and leader with a track record of rapid advancement grounded in proven strategic and communication talents, collaborative skills, and trusted integrity. Alice has deep relationships with California policymakers, thought leaders, and community-based organizations. She leverages her well-honed skills to build consensus, gain buy-in, and motivate team members and partners.

Alice helped to launch the startup state advocacy practice at one of the largest public affairs consultancies on the West Coast, where she worked to advance the interests of technology firms, automakers, trade associations, and local government entities. As managing partner for one of the fastest growing lobbying firms in Sacramento, she oversaw all business operations and represented clients in the areas of energy, technology, health care, and education.

She has led policy and community initiatives in t

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Photo of Michael P. Canavan Michael P. Canavan

Michael P. Canavan is a member of the Environmental Practice at Greenberg Traurig. He focuses his practice on providing counsel on environmental issues associated with real estate and corporate transactions. Michael represents private equity firms, real estate opportunity funds, commercial and residential real…

Michael P. Canavan is a member of the Environmental Practice at Greenberg Traurig. He focuses his practice on providing counsel on environmental issues associated with real estate and corporate transactions. Michael represents private equity firms, real estate opportunity funds, commercial and residential real estate developers, and companies in highly-regulated industries in connection with environmental due diligence, contractual allocation of associated risks and liabilities, insurance procurement, and regulatory compliance. Clients rely on Michael for his ability to quickly identify and evaluate environmental issues arising from the acquisition, financing, ownership, and sale of real property, and he draws on his experience having assisted with hundreds of real estate transactions in the majority of U.S. states, the United Kingdom, the European Union, and Japan.

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Photo of Madeline Orlando Madeline Orlando

Madeline Orlando is a member of the Litigation Practice in Greenberg Traurig’s Sacramento office. She represents clients in environmental matters, focusing on regulatory issues, hazardous waste litigation, and state regulations including California’s Cleaning Product Right to Know Act.

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