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ESG Engagements in 2024 and More.....


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ENVIRONMENTAL


Climate Disclosure Update

June 24, 2024


It is uncertain when or if the SEC’s new climate disclosure rules will come into effect. The ultimate fate of the rules is unclear given the litigation over the rules in the Eighth Circuit. In addition, the SEC recently stayed the rules pending resolution of the litigation. However, as we have said before, “it’s not pencils down on climate disclosure more generally.” Public and private companies need to manage to other current and pending climate disclosure requirements (and other ESG disclosures more generally) at the U.S. federal and state levels as well as outside the United States. As discussed in this piece, even though the SEC’s new climate disclosure rules are on hold and may be scaled back or never implemented, there are other climate disclosure requirements to take into account.



$850 Million Now Available for Methane Emission Reduction Efforts

June 24, 2024


The U.S. Environmental Protection Agency (EPA) and U.S. Department of Energy (DOE) on June 21, 2024, released a $850 million Funding Opportunity Announcement (FOA) to reduce methane emissions from oil and natural gas production and associated facilities. This funding was made available under the Inflation Reduction Act, and applications are due by 5 p.m. ET on Aug. 26, 2024.



EPA’s Proposed NSR Rule for Project Emissions Accounting Will Mean Permitting Delays for Projects and Expansions

June 18, 2024


The NSR program requires facilities to obtain a permit before constructing a new major stationary source or undertaking a “major modification” of an existing major source. EPA’s NSR regulations include a two-step test to determine if an existing major source must obtain an NSR permit for a physical change or a change in the method of operation, often referred to as a “project.”


In November 2020, EPA promulgated the Project Emissions Accounting rule (PEA rule) to clarify the applicable accounting procedures to determine when a physical change or change in the method of operation at a major stationary source would result in a significant emissions increase.1 The PEA rule clarified that both emissions increases and decreases from projects may be considered in Step 1 of the NSR major modification applicability test. This was a significant change, codifying the Project Emissions Accounting interpretation initially issued in a 2018 memorandum from then-Administrator Scott Pruitt.



EPCRA Toxic Release Inventory

June 14, 2024


If your facility manufacturers, processes, or uses hazardous chemicals, you may be required to submit TRI reporting to US EPA by July 1.


See the reporting thresholds, covered chemicals, key regulatory definitions, and how to determine if your facility is covered with this Lion EH&S Cheat Sheet.


Source: Lion


Council on Environmental Quality Substantially Rewrites NEPA Regulations

June 6, 2024


The Council on Environmental Quality (CEQ) recently published its Phase II regulations under the National Environmental Policy Act (NEPA).


Amendments to the NEPA regulations are significant in scope and affect virtually all aspects of the NEPA review process, with many potentially contributing to Biden Administration goals of efficiencies and streamlined reviews, while others possibly burden regulatory agencies and project proponents subject to NEPA review.



Interoperability Guidance Published on ESRS And ISSB Standards

June 5, 2024


On 2 May 2024, the IFRS Foundation and EFRAG together published guidance material on the alignment between the ISSB Standards and ESRS.


The material provides interoperability guidance for climate-related sustainability disclosures under ESRS and ISSB Standards.


Source: EY


Update on The Final SEC Climate-Related Disclosures Rule

June 5, 2024


The Securities and Exchange Commission (SEC) has adopted the long-awaited rule on climate-related financial disclosures. The SEC’s Enhancement and Standardization of Climate-Related Disclosures for Investors requires registrants to disclose certain information about climate-related risks that pertain to a company's business. 3Degrees


Source: 3Degrees


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SOCIAL


Biden-Harris Administration Announces Availability of Nearly $200 Million in Grants to Fix Aging Natural Gas Pipes, Reduce Energy Costs

June 18, 2024


WASHINGTON - The U.S. Department of Transportation’s Pipeline and Hazardous Materials Safety Administration (PHMSA) is soliciting grant applications for nearly $200 million as part of part of a first-of-its-kind program established by President Biden’s historic Bipartisan Infrastructure Law in November 2021. The Natural Gas Distribution Infrastructure Safety and Modernization (NGDISM) grant program, is aimed at mitigating safety risks and methane emissions from high-risk and leak-prone legacy natural gas distribution pipes. To date, the grant program has provided nearly $600 million in funding to create hundreds of good-paying pipeline jobs, help lower energy costs for consumers, and modernize infrastructure that has been around for decades with some from as far back as the Civil War Era.



30 Questions Hazmat Investigators Want to Ask

June 13, 2024


Introduction Questions

1. What are your typical operations? Can you provide a general overview?

2. To the best of your knowledge, was a hazardous material involved in your operations?

3. If yes, please provide the proper shipping name.

General Hazardous Materials (Hazmat) Information

1. Can you describe the hazardous materials in transportation you normally see?

1. How often do you see them?

2. Are you shipping them?

3. Are you storing them?

2. Are there any specific requirements for the condition of the hazardous material that must be followed before the identified material is transported?

3. Have these conditions been verified? If so, what was the method used?

4. Are there modal-specific (rail/air/ vessel/highway) requirements for this hazardous material that you follow? If so, what are they?

5. Do the locations accepting your hazardous material have any concerns/ special accommodations when receiving your hazardous material?

6. Do shipping agents (e.g., insurance companies, shippers) have specific requirements when accepting your hazardous material?

7. Which hazard class(es) of hazardous materials in transportation do you routinely see?

Hazardous Material Training

1. Which employees/departments are trained to be able to handle this hazardous material? Who conducts this training?

2. When was the last time training was provided?

3. How do you determine who needs training?

Safety

1. What have you or your industry done to mitigate risk around this hazardous material?

2. What solutions have been found to be helpful during hazardous materials incidents?

3. How would you handle a hazardous material found to be damaged or not properly packaged?

4. Are there any special requirements in place or instructions when hazardous materials are present?

Emergencies/Incidents

1. Do you have the means to contain the hazardous material if there is an accident or an incident?

2. What remediation companies are potentially contracted at this location or by this company?

3. Are you familiar with security plan requirements?

Industry Process/SOPs

1. Can you identify other companies involved in the transportation of this hazardous material? Can you share their contact information?

2. What are the locations of your hazardous materials operations?

3. Can you share the Standard Operation Procedures (SOP) for the handling of hazardous materials at your company?

4. Are you familiar with registration requirements? e. Who signs and prepares shipping papers?

5. Do you transport any hazardous materials in compliance with an approval or special permit?

6. Do you have any type of validation process for hazardous material shipping?

Carriers/Shippers/Testers/Manufacturers

1. Do you manufacture any hazardous material packaging?

2. Are any other entities involved with the preparation, handling, or transportation of hazardous materials?

Packaging

1. Where do you purchase hazardous materials packaging?

2. Is the product loaded at any specific temperature/pressure?

3. What types of packaging do you routinely see/use for hazardous materials transportation? Including bulk, non-bulk, and/or cylinders.

4. At what interval are you having the package tested? Who performs this function? Are there records?

5. How are you closing the packages? Which tools or other equipment are used?


Source: Lion


GOVERNANCE


ESG Engagements in 2024

June 25, 2024


2024 marks a new frontier for climate reporting, with many companies facing their first calls for regulated disclosure. For companies already confident in their reporting, these developments serve as an opportunity to focus on oversight and materiality.


After two years in the making, the Securities and Exchange Commission’s (SEC) Climate Rule was approved in March, while 2024 marks the first data collection year for the European Commission’s Corporate Sustainable Reporting Directive (CSRD). The past year also saw California call on companies doing business in the state to report on climate risks and opportunities, starting in 2026.


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