Next Week: Tues. Dec. 23 at Noon—AgWorks: Staying Compliant with Anti-Discrimination Laws
National Agricultural Policy: USDA Announces $12 Billion in ‘Bridge Payments’
On December 8, 2025, the U.S. Department of Agriculture (USDA) announced that the agency will distribute $12 billion in Commodity Credit Corporation (CCC) funding for “one time bridge payments” to U.S. farmers
OSHA Cannot Issue Citations Relating to Employee Work on Rail Cars, Eighth Circuit Says
Seyfarth Synopsis: In MFA Enterprises, Inc. v. OSHRC, No. 24-3107 (8th Cir. 2025), the Eighth Circuit Court of Appeals vacated OSHA citations related to hazards faced by employees working on top of rail cars, finding these hazards outside of OSHA’s statutory jurisdiction.
The Federal Railroad Administration (“FRA”) and federal Occupational Safety and Health Administration (“OSHA”)
CARB Kicks Off Holiday Season with Release of Proposed Initial Rule Implementing California Climate Disclosure Laws
On December 9, 2025, the California Air Resources Board (CARB) released a rulemaking package for its proposed “initial regulation” to implement California’s landmark climate disclosure laws: Senate Bill (SB) 253, requiring annual reporting of Scope 1, Scope 2, and Scope 3 greenhouse gas (GHG) emissions, and SB 261, requiring the disclosure of climate-related financial risks. CARB also announced an in-person and virtual public hearing on the proposed rule to be held during the board’s regularly scheduled meeting on February 26, 2026.
Important Updates on California’s Climate Disclosure Laws
California’s climate disclosure laws continue to present novel challenges and twists and turns to regulated businesses, and the past month is no exception. Since our last blog post on this topic, there have been significant developments regarding the implementation of SB 261 and SB 253. On November 18, 2025, the Ninth Circuit Court of Appeals enjoined the California Air Resources Board (CARB) from enforcing SB 261, which requires companies to disclose climate-related financial risks. Importantly, the injunction was issued prior to the January 1 deadline for companies to publish their climate-related financial risk report pursuant to SB 261. On December 1, 2025, CARB issued an Enforcement Advisory confirming it would not enforce against companies for failure to post a climate-related financial risk report on January 1, 2026. Then, on December 9, 2025, CARB posted proposed regulations applicable to SB 253 and SB 261. Further details and considerations are discussed in this blog post.
Federal Judge Vacates Trump Administration’s Halt to Wind Energy Permitting
On December 8, 2025, in the case of New York v. Trump, the federal district court for the District of Massachusetts vacated orders from several federal agencies that implemented a moratorium on permitting and approvals for wind energy projects in response to one of the current administration’s “day one” executive actions. The court vacated
The Release Report #8: Remediation Standards and Regulations
This is the eighth in a series of blog posts discussing key features of Connecticut’s new release-based cleanup regulations (the “RBCRs”), R.C.S.A. § 22a-134tt-1 et seq.
As remediation projects are planned and performed, the big question is: “How clean is clean enough?” This post discusses remediation standards under the RBCRs, and how those standards will
EU Deforestation Regulation Postponed and Simplified: What Companies Need to Know
EPA Issues “Compliance First” Memo: Key Takeaways for Regulated Entities
On December 5, 2025, Craig J. Pritzlaff, Acting Assistant Administrator of the EPA’s Office of Enforcement and Compliance Assurance (OECA), issued an internal memorandum instituting a “Compliance First” approach, immediately effective for all civil enforcement and compliance activities. This memo claims to introduce a policy shift: prioritizing timely and effective compliance over punitive enforcement and
California Chamber of Commerce Advances Pioneering Initiative to Amend CEQA to Streamline Permitting and Construction of “Essential Projects”
On October 21, 2025, the California Chamber of Commerce (the “Chamber”) announced it had filed a voter initiative to modernize and streamline the review process for building the state’s most essential infrastructure projects. On November 25, 2025, the Chamber filed amendments to clarify and add further substance to the provisions of that proposed initiative measure, which is entitled the “Building an Affordable California Act” (“BACA”). BACA would make numerous significant changes to the permitting and CEQA review processes for “Essential Projects,” which are defined therein as specific types of housing, water, clean energy, public health, education, broadband internet access, and transportation projects. In broad strokes, BACA would make five categories of changes to the various review processes for Essential Projects.
Status Update on the AIM Act and EPA’s HFC-Refrigerant Regulations
As we approach the new year, several regulatory initiatives concerning hydrofluorocarbons (HFCs) are on the horizon with major implications to the retail industry with particular impact on the retail food industry. Since ozone depleting substances were phased out of the economy beginning in the 1990s, HFCs have been the most commonly used refrigerant in air