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The CCRcorp Network unlocks access to a world of insights, research, guides and information in a range of specialty areas.

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TheCorporateCounsel

TheCorporateCounsel.net

A basis for research and practical guidance focusing on federal securities laws, compliance & corporate governance.

DealLawyers

DealLawyers.com

An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.

CompensationStandards

CompensationStandards.com

The “one stop” resource for information about responsible executive compensation practices & disclosure.

Section16.net

Section16.net

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.

PracticalESG

PracticalESG.com

Keeping you in-the-know on environmental, social and governance developments

Last month, I wrote about the California Air Resources Board’s (CARB) big changes to the state’s cap-and-invest program. The changes largely weakened the program, but CARB argues this is necessary to fight the rising cost of living. In the blog, I noted that climate activists criticized these amendments. Now, at least one climate activist group is taking CARB to court. The plaintiffs allege that CARB failed to follow appropriate administrative procedure and that its Environmental Impact Assessment (EIA) was deficient, stating in their Complaint:

“The Final EIA fails to adequately disclose or analyze the Project’s impacts on the environment, including but not limited to, the Project’s impacts on human health, greenhouse gases, air quality, utilities and service systems, and energy use. Much of the Final EIA’s analysis is highly generalized. Yet in discussions of certain impacts, such as Air Quality and Greenhouse Gas Emissions, the Final EIA makes numeric predictions and assessments without any revision addressing the changes to the MDI.”

The chief concern of the plaintiffs is the addition of carbon allowances into the cap-and-invest system. While the initial CARB changes sought to remove 118 million carbon allowances, the agency added back 118 million allowances through its “Manufacturing Decarbonization Incentive” (MDI). Plaintiffs believe that this is the wrong kind of “net-zero” approach and that CARB did not adequately assess the impact of adding back the allowances. Ultimately, it’s in the hands of the courts to determine if the plaintiff’s case has merit. With climate ambitions being scaled back at the state level, we can likely expect more lawsuits attempting to hold states to their original climate ambitions.

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The Editor

Zachary Barlow is a licensed attorney. He earned his JD from the University of Mississippi and has a bachelor’s in Public Policy Leadership. He practiced law at a mid-size firm and handled a wide variety of cases. During this time he assisted in overseeing compliance of a public entity and litigated contract disputes, gaining experience both in and outside of the courtroom. Zachary currently assists the PracticalESG.com editorial team by providing research and creating content on a spectrum of ESG… View Profile