In September 2025, California extended and amended authority for its statewide greenhouse gas (GHG) “cap and trade” program through 2045 – and rebranded it as “cap and invest.” The California Air Resources Board (ARB) has administered this program since 2012, as part of broader GHG reduction provisions created by 2006’s Assembly Bill (AB) 32. AB 32 initially committed the state to reduce total GHG emissions back to 1990 levels by 2020 (achieved in 2018); ARB’s latest GHG reduction scoping plan (issued in 2022), seeks to reduce statewide emissions to 85% below 1990 levels by 2045, achieving carbon neutrality. Subsequent legislation extended implementing authority for cap-and-trade and other related programs available to the California Air Resources Board (ARB) and other agencies through 2030. (I wrote about that extension (AB 398) HERE ). The newest legislation (AB 2017 and Senate Bill (SB) 840) continues the state’s GHG reduction efforts by making further changes to ARB’s cap and trade authority. The rest of this note summarizes these changes.
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California Extends and Amends its Greenhouse Gas Cap and Trade Program
Posted by Jon Elliott on Fri, Oct 17, 2025
Tags: climate change, sustainability, cap-and-trade, California, Climate, Carbon markets, Environmental Compliance, Climate Risk, California Regulations, Greenhouse Gas Emissions, GHG Reduction, cap-and-invest, California Air Resources Board
EPA proposes to eliminate most mandatory greenhouse gas emission reporting requirements
Posted by Jon Elliott on Fri, Oct 03, 2025
On September 16, 2025, the US Environmental Protection Agency (EPA) published a proposal to eliminate the vast majority of its longstanding Greenhouse Gas Reporting Program (GHGRP), which requires thousands of facilities and organizations to report annual emissions of greenhouse gases (GHGs) (40 CFR part 98). (I’ve written about this program over the years, most recently when EPA issued massive revisions in April 2024 (see HERE). The remainder of this note briefly summarizes EPA’s latest interpretation and identifies the small portion EPA proposes to retain, and the existing GHGRP.
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Tags: EPA, Greenhouse Gas, Clean Air Act, Climate, Environmental Compliance, EPA Regulations, EPA Standards, GHG Reporting, EPA enforcement, Climate Disclosure, Climate Risk, Air Quality
SEC ends legal defense of climate-related disclosure requirements for public companies
Posted by Jon Elliott on Thu, May 15, 2025
On March 27, 2025 the US Securities and Exchange Commission (SEC) voted to stop defending rules adopted in 2024 (during the Biden administration) that would have required selected “public companies” (i.e, listed on national securities exchanges) to provide “climate-related disclosures for investors” in their registration statements and annual reports. SEC had stayed these rules’ effectiveness after being sued by two energy companies, which were later joined by other plaintiffs as well as state and nonprofit supporters of the rules. The latest SEC decision ends the agency’s defense in that litigation.
Read MoreTags: SEC, Environmental Policy, Climate, ESG, Environmental Compliance, Risk Management, Sustainability Reporting, Climate Disclosure, Climate Risk