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Environmental
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economic
Socio-
environmental
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efficiency
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• Waste and recycling
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Social
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ESG CONSULTING
ESG is more than a report you file and forget—it’s a transparent, data-driven, and forward-looking business management strategy that is proven to create value.
No matter where you are on your ESG journey, Langan can help you prepare for current and future stakeholder demands and regulatory requirements.
Langan offers a comprehensive portfolio of integrated ESG services, including ESG disclosures/reporting, carbon accounting, ESG strategy development and implementation, M&A due diligence, data acquisition and management, and sustainable development support.
We create efficient, cost-effective solutions that complement and enhance the operations and growth plans of our clients. Our team of experts is here to help you identify, develop, and implement ESG solutions that are right for you and your firm.
What is ESG?
Hover over the graphic below to learn more
are a set of criteria used by responsible investors and customers to assess a company’s overall health and resiliency. Environmental criteria communicate a company’s impact on the environment and how it plans to address pressing issues such as climate risk, waste management, and energy transition. Social criteria examine a company’s relationship with its employees, clients, and the communities in which it operates. Governance criteria deal with a company’s leadership and how it operates.
It’s important to get it and get it right!
Environmental, Social, and Governance
Our Full-Service Approach to ESG
Our ESG Services
ESG Education
& Outreach
ESG Transactional
Due Diligence
ESG Rankings
& Disclosures
Carbon Accounting
& Target Setting
Digital ESG Solutions
Sustainable Design
• LEED and Green Building Design
• Fuel Switching/Substitution Support
• Mapping and discovery of ESG data streams
• EHS and ESG software/technology
selection and implementation support
• Design of data acquisition and data quality
control processes
• Data management systems integration
and automation
• Portfolio ESG assessment
• Buy side / sell side ESG consulting
• ESG reputational risk identification
• Post-merger and acquisition integration
ESG support
• Scope 1, 2, and 3 GHG quantification
• Product life cycle assessments (LCAs)
• GHG emission reduction target setting
• Net-zero strategy development and
implementation support
• Science Based Target Initiative support
• Alignment with industry accepted
frameworks and standards (GRI, SASB,
TCFD, GHG Protocol)
• Assistance with responses to ESG rating
system questionnaires (CDP, MSCI, S&P
Global, EcoVadis, etc.)
• Customized ESG training for leaders and
key stakeholders
• Facilitated ESG strategy sessions
for executives
Engage with leaders and key stakeholders to evaluate existing ESG practices and provide ESG education to build a common knowledge base.
Framing
& Engagement
Identify and rank industry relevant ESG issues, examine available data and metrics, benchmark against peers, and identify potential risks and opportunities for improvement.
Materiality & Gap Analysis
ESG Strategy Development
Work with key stakeholders to implement ESG solutions, coordinating with both in-house and third-party experts, and track progress towards
ESG goals.
ESG Solution Implementation
1
1
2
3
4
ESG INTEL
...On Supreme Court Limiting EPA’s Authority
to Regulate Greenhouse Gas Emissions
New York, NY
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
READ MORE
NEXT >
ESG INTEL
...On Supreme Court Limiting EPA’s Authority to Regulate Greenhouse Gas Emissions
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
Application of the “Major Questions Doctrine”
This ruling solidified the Supreme Court’s application of the “major questions doctrine” to EPA regulations. This doctrine holds that government agencies cannot adopt rules that are “transformational” to the economy unless Congress has specifically authorized it. The major questions doctrine is not a new concept. It has been developing in judicial opinions for years as EPA proposes regulations with progressively broader reach and judges remind EPA its authority is limited to regulating in accordance with Congressional legislation. As environmental legislation has aged, EPA has faced challenges developing regulations that keep pace with emerging technology and environmental issues without crossing the line to legislating without authority. For example, the Clean Air Act was enacted over 30 years ago and it does not explicitly provide regulation of GHGs. The current EPA GHG regulations were established by complex arguments that the Clean Air Act implicitly provided for GHG regulation.
Now that the Supreme Court has drawn a line for EPA authority, does this mean there will be no GHG regulation at all? No. Federal agencies, including EPA, can still issue regulations as long as they are not “transformational” to the economy. However, the extent to which a regulation is deemed “transformational” remains to be seen.
Frequent Use of the Doctrine Anticipated
We now know that the EPA broadly limiting how power can be generated is considered transformational, but what else will be affected by this ruling? What about the proposed Securities Exchange Commission rule requiring that public companies must report both GHG emissions and climate-related risks? What about the Federal Energy Regulatory Commission interim policy stating that GHG emissions and their contributions to climate change should be addressed at the same level as other environmental impacts? These agencies regulate different activities and a different range of companies than EPA, but it should be expected that their regulations will be subjected to the major questions doctrine as well, and the result will not be known until challenges are made and litigated.
The frequent use of the major questions doctrine to challenge federal regulations has already begun. Within a week of the ruling, the State of Texas cited the major questions doctrine in an argument against the Nuclear Regulatory Commission (NRC). The state challenged NRC’s authority to license a radioactive waste storage facility in Texas, arguing the underlying legislation does not regulate the storage of spent nuclear fuel.
Expected Impacts
In addition to subjecting current and proposed regulations to new scrutiny, this restraint on federal GHG regulation will likely create fractured regulations across the US as states unwilling to wait for federal Congressional action begin enacting their own rules.
To predict the practical impact of this fracturing, we can look at oil and gas production regulations. When EPA rolled back and/or rescinded many of the June 3, 2016 Clean Air Act methane reduction regulations for oil and gas facilities from 2017 to 2020, states like Colorado and New Mexico introduced their own regulations. This resulted in a confusing mix of operational requirements that necessitated the development of multiple compliance programs for companies doing business in multiple states. Another impact of managing different regulatory requirements is the potential backlash to companies simply complying with state-specific regulations. Are they undervaluing the health and safety of employees in less regulated states because they are only applying clearly feasible practices in those that are more highly regulated?
The Supreme Court ruling will likely result in a significant reduction of federal environmental compliance costs, but don’t assume that this will lead to bottom-line savings. Instead, companies may need to invest that time and money into tracking court movements, following state rules, and convincing stakeholders that their approach to each unique regulatory situation is sound.
BACK TO HOMEPAGE
What is ESG?
Our ESG Intel
Our Approach
Our Services
Our Team
Written by Leslie Wong and Hussein Sayani
Our ESG Services
• Assistance with responses to ESG rating
system questionnaires (CDP, MSCI, S&P
Global, Ecovadis, etc.) for benchmarking
& disclosure purposes
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Stakeholders are increasingly demanding compelling and actionable ESG strategies. Disclosing and improving performance on ESG metrics is correlated to financial performance and long-term value creation.
• ESG disclosure and benchmarking support
• Shoreline, Flood, & Storm Resiliency
Planning
• Ecological Restoration and Wetlands
Mitigation
• Sustainable Landscape Architecture
• Assistance with responses to ESG rating
system questionnaires (CDP, MSCI, S&P
Global, EcoVadis, etc.)
• Fuel Switching/Substitution Support
• Shoreline, Flood, & Storm Resiliency
Planning
• Ecological Restoration and Wetlands
Mitigation
• Green and Sustainable Remediation
ESG INTEL
...On Greenwashing
New York, NY
Media, lawmakers, and consumers are increasingly using the term “greenwashing” to criticize companies and products marketed as more environmentally beneficial than they actually are. Greenwashing is being used to describe a range of embellishments from minor cases like companies that include splashy greenhouse gas (GHG) emissions reduction stories in their ESG reports while burying the fact that their overall...
READ MORE
ESG INTEL
...On Greenwashing
Written by Leslie Wong and Hussein Sayani
Media, lawmakers, and consumers are increasingly using the term “greenwashing” to criticize companies and products marketed as more environmentally beneficial than they actually are. Greenwashing is being used to describe a range of embellishments from minor cases like companies that include splashy greenhouse gas (GHG) emissions reduction stories in their ESG reports while burying the fact that their overall GHG emissions increased, to major cases like presenting an investment fund as “low carbon” when it has no low carbon attributes whatsoever. So, what exactly does greenwashing mean and are there any legal ramifications for companies that engage in it?
The term greenwashing was coined by environmentalist Jay Westerveld in the mid-1980s to describe the hotel industry’s ethically dubious, but not illegal, practice of asking guests to reuse towels to cut costs under the guise of protecting the planet. The term made its first appearance as a defined and actionable offense nearly a decade later in “The Green Guide,” published the Federal Trade Commission (FTC) in 1992. The guide, which is still in use today, provides companies with guidelines for making environmental marketing claims and how to qualify those claims.
The FTC defines greenwashing as intentionally misleading consumers on environmental attributes of a product or service, e.g., committing fraud using environmental misinformation. The FTC has the authority to impose significant monetary penalties and force companies to cease deceptive practices if they are found to be greenwashing.
The frequency of misleading environmental disclosures continues to increase as investors become more environmentally conscious. Not all of these misleading disclosures are, or can be demonstrated to be, intentional or untrue and actionable by the FTC. Some of these misleading disclosures, particularly those associated with GHG emissions and reduction targets, are made in good faith by companies that are not educated in GHG management methods and the correct application of its terminology. However, the term greenwashing encompasses those types of companies, as well as companies that make misleading, fraudulent statements. This means that the same word can refer to a minor misunderstanding, a potentially criminal action, and anything in between. No wonder everyone is confused!
That being said, is it appropriate to call such a wide range of claims “greenwashing”? Probably not, because the term no longer communicates the severity of a problematic claim. Severity could be communicated by specifying whether the greenwashing was “intentional” or “unintentional,” but that does not capture the wide and subtle range of misinformation being disclosed. Severity could be communicated by specifying if the greenwashing is “FTC actionable” or “not FTC actionable” but the FTC does not have jurisdiction over those communications. We need new terminology and clear guidelines on where the line of legality sits.
Investors and other stakeholders are increasingly demanding GHG management and disclosure from the companies they do business with, dramatically expanding the number of companies engaging in the practice. In the absence of clear, mandatory standards in the form of legislation and/or regulation, it is inevitable that some companies will stretch the definitions of the voluntary ESG reporting guidelines now being used. Clarification on what constitutes as greenwashing may not be imminent, but regulation has already been proposed.
On March 21, 2022, the Securities and Exchange Commission (SEC) proposed a rule that would require all SEC-registered companies to disclose climate change-related risks and GHG inventories. Then, on May 25, 2022, the SEC proposed a rule that would require marketers of funds identified as ESG-focused to disclose information demonstrating their environmental benefits, including the GHG inventory of their investments. For one business category, this rule would clearly define legal boundaries for environmental disclosures.
The Origin of “Greenwashing”
Defining the Term
Demands for Regulation
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ESG INTEL
...On Supreme Court Limiting EPA’s Authority to Regulate Greenhouse Gas Emissions
Written by Leslie Wong
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
This ruling solidified the Supreme Court’s application of the “major questions doctrine” to EPA regulations. This doctrine holds that government agencies cannot adopt rules that are “transformational” to the economy unless Congress has specifically authorized it. The major questions doctrine is not a new concept. It has been developing in judicial opinions for years as EPA proposes regulations with progressively broader reach and judges remind EPA its authority is limited to regulating in accordance with Congressional legislation. As environmental legislation has aged, EPA has faced challenges developing regulations that keep pace with emerging technology and environmental issues without crossing the line to legislating without authority. For example, the Clean Air Act was enacted over 30 years ago and it does not explicitly provide regulation of GHGs. The current EPA GHG regulations were established by complex arguments that the Clean Air Act implicitly provided for GHG regulation.
Now that the Supreme Court has drawn a line for EPA authority, does this mean there will be no GHG regulation at all? No. Federal agencies, including EPA, can still issue regulations as long as they are not “transformational” to the economy. However, the extent to which a regulation is deemed “transformational” remains to be seen.
We now know that the EPA broadly limiting how power can be generated is considered transformational, but what else will be affected by this ruling? What about the proposed Securities Exchange Commission rule requiring that public companies must report both GHG emissions and climate-related risks? What about the Federal Energy Regulatory Commission interim policy stating that GHG emissions and their contributions to climate change should be addressed at the same level as other environmental impacts? These agencies regulate different activities and a different range of companies than EPA, but it should be expected that their regulations will be subjected to the major questions doctrine as well, and the result will not be known until challenges are made and litigated.
The frequent use of the major questions doctrine to challenge federal regulations has already begun. Within a week of the ruling, the State of Texas cited the major questions doctrine in an argument against the Nuclear Regulatory Commission (NRC). The state challenged NRC’s authority to license a radioactive waste storage facility in Texas, arguing the underlying legislation does not regulate the storage of spent nuclear fuel.
In addition to subjecting current and proposed regulations to new scrutiny, this restraint on federal GHG regulation will likely create fractured regulations across the US as states unwilling to wait for federal Congressional action begin enacting their own rules.
To predict the practical impact of this fracturing, we can look at oil and gas production regulations. When EPA rolled back and/or rescinded many of the June 3, 2016 Clean Air Act methane reduction regulations for oil and gas facilities from 2017 to 2020, states like Colorado and New Mexico introduced their own regulations. This resulted in a confusing mix of operational requirements that necessitated the development of multiple compliance programs for companies doing business in multiple states. Another impact of managing different regulatory requirements is the potential backlash to companies simply complying with state-specific regulations. Are they undervaluing the health and safety of employees in less regulated states because they are only applying clearly feasible practices in those that are more highly regulated?
The Supreme Court ruling will likely result in a significant reduction of federal environmental compliance costs, but don’t assume that this will lead to bottom-line savings. Instead, companies may need to invest that time and money into tracking court movements, following state rules, and convincing stakeholders that their approach to each unique regulatory situation is sound.
Application of the “Major Questions Doctrine”
Frequent Use of the Doctrine Anticipated
Expected Impacts
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We create efficient, cost-effective solutions that complement and enhance the operations and growth plans of our clients. Our team of experts is here to help you identify, develop, and implement ESG solutions that are right for you and your firm.
ESG INTEL
..On Identifying Weak Links in Your ESG Program
New York, NY
Environmental, Social, and Governance (ESG) disclosures have evolved beyond reporting operational metrics like carbon emissions, employee professional development, and board diversity. Today's corporate disclosures encompass an increasingly complex landscape of climate-related risks, opportunities, and targets. Yet companies often focus exclusively on external risk factors such as extreme weather events and shifting markets, neglecting internal policies and practices.
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ESG INTEL
...On Reducing GHG Emissions and Offsetting Carbon
New York, NY
One of the most controversial topics in ESG management is the acceptable methods of greenhouse gas (GHG) emissions reduction. While it may seem odd that reducing GHG emissions could ever be considered unacceptable, not all GHG reduction methods are legitimate. In fact, illegitimate reductions fall into the realm of greenwashing. For a GHG reduction to be considered legitimate, it must be permanent, accurately measured or estimated, and not claimed by another party.
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ESG INTEL
...On Reducing GHG Emissions and Offsetting Carbon
Written by Leslie Wong
One of the most controversial topics in ESG management is the acceptable methods of greenhouse gas (GHG) emissions reduction. While it may seem odd that reducing GHG emissions could ever be considered unacceptable, not all GHG reduction methods are legitimate. In fact, illegitimate reductions fall into the realm of greenwashing. For a GHG reduction to be considered legitimate, it must be permanent, accurately measured or estimated, and not claimed by another party.
GHG emissions reduction methods fall into one of three categories:
1. Avoiding or mitigating emissions
2. Offsetting via carbon credits
3. Carbon capture and sequestration
In carbon management, a premium is placed on the avoidance of GHG emissions as they are not subject to the same strict accounting requirements as the other GHG reduction methods. For example, leaks from a carbon capture, utilization and storage process or discovery that are not represented in an advertised GHG reduction by a purchased carbon offset can result in those reductions being either partially or fully canceled.
The term greenwashing was coined by environmentalist Jay Westerveld in the mid-1980s to describe the hotel industry’s ethically dubious, but not illegal, practice of asking guests to reuse towels to cut costs under the guise of protecting the planet. The term made its first appearance as a defined and actionable offense nearly a decade later in “The Green Guide,” published the Federal Trade Commission (FTC) in 1992. The guide, which is still in use today, provides companies with guidelines for making environmental marketing claims and how to qualify those claims.
There are two primary ways to avoid GHG emissions: by mitigating leaks or releases of GHGs to the atmosphere, or by reducing fossil fuel-based energy use. Most people associate GHG leaks with natural gas leaks and venting by the oil and gas industry, and link methane leaks to animal agriculture and solid waste landfills. However, two additional sources of potent GHG leaks are used in our daily lives: air conditioning units and refrigerators; the refrigerants that help cool these devices are high global-warming-potential chemicals.
Generating energy by burning fossil fuels, particularly in small and inefficient combustion units, produces large amounts of GHG emissions. By switching to renewable energy sources like wind or solar, or using alternative fuels like ammonia or hydrogen, fossil fuel usage is reduced and significant GHG reductions occur. Yet these solutions are not always viable given a company’s energy demand, location, and/or budget. Regardless of the source, improving energy efficiency through insulation, optimized logistics, and waste heat recovery can also significantly reduce GHG emissions.
Compared to reducing emissions, offsetting GHG emissions is an easier option. However, navigating the market is challenging as the quality of GHG offset programs varies considerably. High quality offset programs use a rigorous application and demonstration process involving multiple levels of third-party data validation. These programs require reductions to be accurately measured or estimated, demonstrated as permanent, not claimed by another party, and voluntary (meaning they are not required by regulation). Under these programs, reduction projects must also demonstrate that they are not associated with significant social or environmental harms other than climate change impacts to generate salable offsets. In contrast, low quality offset programs involve very little validation. As companies rush to set emission reduction and net-zero targets, it is important to note that the Science Based Targets Initiative does not allow offsets to be included in a reduction target until all other options for avoiding GHG emissions have been applied and exhausted.
The existence of low quality GHG offsets and the encouragement of GHG emissions avoidance over offsetting does not mean that carbon offsetting is an illegitimate way to reduce GHG emissions. Rather, GHG offset purchases should be made with caution and attention to how they were generated, and they should not be a company’s only method of reducing emissions. Reducing GHG emissions is difficult, yet important, work that requires taking into consideration many different environmental, social, and business factors. It is a controversial topic because no two companies will take the exact same approach. However, this should not be viewed as inconsistency, but instead as a demonstration that there is no “one-size-fits-all” solution. Companies need to employ the full range of legitimate emissions reduction solutions to prevent the worst effects of climate change—and the depth of possible solutions provides companies the flexibility to choose the GHG reduction path that works best.
How To: Reduce Emissions
How To: Offset Emissions
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Leslie Wong specializes in ESG strategy/disclosure, energy efficiency, and carbon accounting. She has 30 years of experience in environmental management with a specific focus on ESG services over the past 15 years.
ESG INTEL
...On Developing a Holistic ESG Program
Written by Hussein Sayani
Over the last two decades, investing guided by corporate environmental, social, and governance (ESG) principles has become a $35 trillion industry. Investors are increasingly relying on ESG disclosures and scoring to guide decision-making and stakeholders are demanding progress across ESG metrics—particularly on issues relating to climate change, diversity, and equity. And research backs up this shift toward ESG; investing trends show that companies with positive ESG scores outperformed across global markets.
ESG is not a new concept. Rather, it’s a continually evolving business management strategy that shifts focus from short-term profits to long-term viability through consistent and sustainable growth and stakeholder engagement. ESG incorporates existing environmental, health, and safety policies, responsible risk management, ethical corporate governance, and social responsibility into one proactive and forward-looking framework. In this sense, Langan has built expertise in individual ESG aspects since the 1980s. Now, Langan leverages this expertise to provide an integrated set of services that advance the ESG goals of our clients.
A holistic approach to developing an ESG program begins with education, as the success of any program relies on building a common language and understanding among key leaders and stakeholders. The next step is determining which ESG issues are material (or relevant to the company) and which require more work. Scheduling and budgeting the performance of this work forms an ESG strategy that not only accomplishes established goals but also leverages the benefits derived from them.
The projects executed to advance an ESG program can range from tracking ESG metrics (e.g., greenhouse gas emissions, water usage, waste production, diversity and inclusion), to making ESG disclosures to stakeholders, to applying sustainable design during company expansions. While the type of projects needed to support an ESG program vary, they all work toward a single goal: to enhance a company’s long-term economic and social stability.
Hussein Sayani is a climate scientist with 10+ years of experience in climate change research, data analysis, and project management. He specializes in working with companies to develop ESG strategy and disclosures, GHG inventories and reduction targets, and product life cycle analyses.
BACK TO HOMEPAGE
Share on Social Media!
ESG INTEL
...On Greenwashing
New York, NY
Media, lawmakers, and consumers are increasingly using the term “greenwashing” to criticize companies and products marketed as more environmentally beneficial than they actually are. Greenwashing is being used to describe a range of embellishments from minor cases like companies that include splashy greenhouse gas (GHG) emissions reduction stories in their ESG reports while burying the fact that their overall...
READ MORE
ESG INTEL
...On Supreme Court Limiting EPA’s Authority
to Regulate Greenhouse Gas Emissions
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
READ MORE
Share on Social Media!
ESG INTEL
...On Supreme Court Limiting EPA’s Authority to Regulate Greenhouse Gas Emissions
Written by Leslie Wong and Hussein Sayani
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
This ruling solidified the Supreme Court’s application of the “major questions doctrine” to EPA regulations. This doctrine holds that government agencies cannot adopt rules that are “transformational” to the economy unless Congress has specifically authorized it. The major questions doctrine is not a new concept. It has been developing in judicial opinions for years as EPA proposes regulations with progressively broader reach and judges remind EPA its authority is limited to regulating in accordance with Congressional legislation. As environmental legislation has aged, EPA has faced challenges developing regulations that keep pace with emerging technology and environmental issues without crossing the line to legislating without authority. For example, the Clean Air Act was enacted over 30 years ago and it does not explicitly provide regulation of GHGs. The current EPA GHG regulations were established by complex arguments that the Clean Air Act implicitly provided for GHG regulation.
Now that the Supreme Court has drawn a line for EPA authority, does this mean there will be no GHG regulation at all? No. Federal agencies, including EPA, can still issue regulations as long as they are not “transformational” to the economy. However, the extent to which a regulation is deemed “transformational” remains to be seen.
We now know that the EPA broadly limiting how power can be generated is considered transformational, but what else will be affected by this ruling? What about the proposed Securities Exchange Commission rule requiring that public companies must report both GHG emissions and climate-related risks? What about the Federal Energy Regulatory Commission interim policy stating that GHG emissions and their contributions to climate change should be addressed at the same level as other environmental impacts? These agencies regulate different activities and a different range of companies than EPA, but it should be expected that their regulations will be subjected to the major questions doctrine as well, and the result will not be known until challenges are made and litigated.
The frequent use of the major questions doctrine to challenge federal regulations has already begun. Within a week of the ruling, the State of Texas cited the major questions doctrine in an argument against the Nuclear Regulatory Commission (NRC). The state challenged NRC’s authority to license a radioactive waste storage facility in Texas, arguing the underlying legislation does not regulate the storage of spent nuclear fuel.
Application of the “Major Questions Doctrine”
Frequent Use of the Doctrine Anticipated
BACK TO HOMEPAGE
Share on Social Media!
ESG INTEL
...On Supreme Court Limiting EPA’s Authority to Regulate Greenhouse Gas Emissions
Written by Leslie Wong and Hussein Sayani
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
BACK TO HOMEPAGE
Over the last two decades, investing guided by corporate environmental, social, and governance (ESG) principles has become a $35 trillion industry. Investors are increasingly relying on ESG disclosures and scoring to guide decision-making and stakeholders are demanding progress across ESG metrics—particularly on issues relating to climate change, diversity, and equity. And research backs up this shift toward ESG; investing trends show that companies with positive ESG scores outperformed across global markets.
ESG is not a new concept. Rather, it’s a continually evolving business management strategy that shifts focus from short-term profits to long-term viability through consistent and sustainable growth and stakeholder engagement. ESG incorporates existing environmental, health, and safety policies, responsible risk management, ethical corporate governance, and social responsibility into one proactive and forward-looking framework. In this sense, Langan has built expertise in individual ESG aspects since the 1980s. Now, Langan leverages this expertise to provide an integrated set of services that advance the ESG goals of our clients.
A holistic approach to developing an ESG program begins with education, as the success of any program relies on building a common language and understanding among key leaders and stakeholders. The next step is determining which ESG issues are material (or relevant to the company) and which require more work. Scheduling and budgeting the performance of this work forms an ESG strategy that not only accomplishes established goals but also leverages the benefits derived from them.
The projects executed to advance an ESG program can range from tracking ESG metrics (e.g., greenhouse gas emissions, water usage, waste production, diversity and inclusion), to making ESG disclosures to stakeholders, to applying sustainable design during company expansions. While the type of projects needed to support an ESG program vary, they all work toward a single goal: to enhance a company’s long-term economic and social stability.
Hussein Sayani is a climate scientist with 10+ years of experience in climate change research, data analysis, and project management. He specializes in working with companies to develop ESG strategy and disclosures, GHG inventories and reduction targets, and product life cycle analyses.
NVIRONMENTAL
OCIAL
OVERNANCE
E
S
G
ESG INTEL
...On Proposed Regulations Affecting Large GHG Emitters
During the 27th Conference of the Parties to the United Nations Framework Convention on Climate Change, President Biden announced two proposed regulations on specific categories of large greenhouse gas (GHG) emitters, along with funding for multiple climate change initiatives. These regulations would impose specific measures to reduce methane emissions in the oil and gas industry...
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ESG INTEL
...On Supreme Court Limiting EPA’s Authority
to Regulate Greenhouse Gas Emissions
On June 30, 2022, the Supreme Court of the United States issued a ruling that curtails the EPA’s ability to regulate greenhouse gas (GHG) emissions outside the fenceline of new power plants under the Clean Air Act of 1990. Specifically, the Court said that EPA does not have the authority to create a GHG cap-and-trade system for existing power plants absent specific Congressional approval.
READ MORE
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• Green and Sustainable Remediation
>
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ESG INTEL
...On Why Companies Need an Effective
ESG Program Now More Than Ever
Investors, customers, and other stakeholders are increasingly seeking Environmental, Social, and Governance (ESG) disclosures, which communicate a company’s performance on environmental impacts; diversity, equity, and inclusion; and ethics and oversight. The global ESG reporting landscape is rapidly shifting from voluntary reporting to mandatory disclosures.
NEXT >
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ESG INTEL
...On Proposed Regulations Affecting Large GHG Emitters
During the 27th Conference of the Parties to the United Nations Framework Convention on Climate Change, President Biden announced two proposed regulations on specific categories of large greenhouse gas (GHG) emitters, along with funding for multiple climate change initiatives. These regulations would impose specific measures to reduce methane emissions in the ...
NEXT >
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ESG INTEL
...On An Additional California Climate Change Disclosure Rule
California Governor Gavin Newsome gained worldwide attention when he signed legislation on October 7, 2023, requiring high-revenue companies doing business in California to report Scope 1, 2, and 3 greenhouse gas (GHG) emissions and climate-related risks by 2026. He also signed a third GHG-related action, SB1305, which targets the voluntary carbon offset market.
NEXT >
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ESG INTEL
Investors, customers, and other stakeholders are increasingly seeking Environmental, Social, and Governance (ESG) disclosures, which communicate a company’s performance on environmental impacts; diversity, equity, and inclusion; and ethics and oversight. The global ESG reporting landscape is rapidly shifting from voluntary reporting to mandatory disclosures.
NEXT >
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Recommend ESG solutions, design a roadmap for implementing solutions, and develop key performance indicators for tracking progress.
ESG INTEL
...On Moving Forward with ESG Reporting Despite Delayed SEC Climate Rule
In 2022, the U.S. Securities and Exchange Commission (SEC) proposed a set of sweeping climate disclosure rules to standardize how the companies traded on its platform report their environmental, social, and governance (ESG) data. The proposed disclosures include greenhouse gas (GHG) emissions, energy consumption, climate risks, climate-related targets, and other climate-related metrics.
NEXT >
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ESG INTEL
...On Moving Forward with ESG Reporting Despite Delayed SEC Climate Rule
In 2022, the U.S. Securities and Exchange Commission (SEC) proposed a set of sweeping climate disclosure rules to standardize how the companies traded on its platform report their environmental, social, and governance (ESG) data. The proposed disclosures include greenhouse gas (GHG) emissions, energy consumption, climate risks, climate-related targets, and other climate-related metrics.
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In 2022, the U.S. Securities and Exchange Commission (SEC) proposed a set of sweeping climate disclosure rules to standardize how the companies traded on its platform report their environmental, social, and governance (ESG) data. The proposed disclosures include greenhouse gas (GHG) emissions, energy consumption, climate risks, climate-related targets, and other climate-related metrics.
ESG INTEL
...On SEC Climate Change Discolsure Rule - New Anticipated Approval Date
Following the Securities and Exchange Commission’s (SEC) proposed rule to compel more in-depth climate change disclosure by its registrants released on April 11, 2022, the issue of when the rule would be finalized has created controversy. Predictions from regulatory commentators ranged from “never” to “late 2022” with equal gusto and very different assumptions.
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ESG INTEL
Following the Securities and Exchange Commission’s (SEC) proposed rule to compel more in-depth climate change disclosure by its registrants released on April 11, 2022, the issue of when the rule would be finalized has created controversy. Predictions from regulatory commentators ranged from “never” to “late 2022” with equal gusto and very different assumptions.
...On SEC Climate Change Disclosure Rule - New Anticipated Approval Date
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ESG INTEL
...On the Potential Impacts of Emerging State Climate-Related Disclosure Legislation on US Businesses
California, New York, and Washington State have worked through 2023 to advance their own climate disclosure requirements ahead of the Securities and Exchange Commission’s (SEC) climate disclosure rule, which is expected to be authorized by the end of October 2023.
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Our Team
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Rory Johnston
Managing Principal
Leslie Wong
Senior Associate
Hussein Sayani
Senior Project Manager
Amy Drewing
Senior Project Manager
Erin Hansen
Senior Project Manager
Chris Glenn
Associate
Gary Hacker
Senior Project Manager
Michael Patterson
Senior Project Scientist
Gary Bacon
Senior Associate
Devesh Sinha
Associate Principal
Devesh Sinha, PMP, SCJP, Lean Sensei
Associate Principal | dsinha@langan.com
Devesh Sinha is an EHS Business Transformation Consultant with a focus on information management-based EHS process optimization. He has a strong track record of guiding private and public sector clients through the selection and implementation of technology that aligns with their strategic goals
Projects
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Digital Solutions
Geographic Information Systems
Gary Bacon, PE, MBA
Senior Associate | gbacon@langan.com
Gary Bacon has managed environmental engineering, design, procurement, permitting, and compliance assurance for a broad range of industries. His experience includes regulatory applicability determinations, environmental permitting, compliance audits, air emissions inventories, licensing support of energy facilities, and implementation of EHS management information systems at public and private sector facilities throughout the US.
Projects
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Digital Solutions
Geographic Information Systems
Michael Patterson
Senior Project Scientist | mpatterson@langan.com
Michael Patterson has 30 years of multi-disciplinary experience assisting clients with a wide range of ESG consulting services related to mergers, acquisitions, and divestitures. He works closely with manufacturing, oil & gas, chemical, pharmaceutical, legal, insurance, real estate, private equity, and banking clients to identify material areas of concern and compliance issues related to transactions.
Projects
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Digital Solutions
Geographic Information Systems
Gary Hacker, CPEA, LEED AP
Senior Project Manager | ghacker@langan.com
Gary Hacker has 40 years of experience in the areas of environmental due diligence and environmental compliance assessments. He works with private equity, legal, industrial, and commercial investment clients to provide strategic support throughout the deal cycle. He has successfully completed portfolio due diligence projects on a global scale and has led clients to achieve the best possible outcome.
Projects
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Digital Solutions
Geographic Information Systems
Chris Glenn, PE, LEED GA, ENV SP
Associate | cglenn@langan.com
Chris Glenn has over 20 years of experience providing environmental engineering and sustainable development solutions for clients. He serves as Langan’s Sustainability Director, leading the implementation of Langan’s corporate sustainability program to improve the environmental and social performance of our internal operations. He assists clients with sustainable site design, reducing embodied carbon of design, GHG inventory and offset, and ESG program development.
Projects
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Digital Solutions
Geographic Information Systems
Erin Hansen
Senior Project Manager | ehansen@langan.com
Erin Hansen is an environmental engineer with 10 years of combined experience in ESG and air quality. She works with oil & gas, steel, and a variety of other industries, specializing in quantifying air emissions – including GHG emissions – from complex sources. Her focus areas include air permitting and regulatory compliance, process simulation, carbon accounting, and emission inventory preparation.
Projects
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Digital Solutions
Geographic Information Systems
Amy Drewing
Senior Project Manager | adrewing@langan.com
Amy Drewing has over 18 years of environmental consulting experience specializing in ESG, mergers and acquisitions, and compliance support. She has extensive expertise in providing Phase I and Phase II Environmental Site Assessments; Environmental, Health, Safety, and Sustainability auditing; industrial hygiene; industrial health and safety program management; health and safety planning and oversight for construction, remediation, and demolition activities; and more.
Projects
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Digital Solutions
Geographic Information Systems
Hussein Sayani, PhD
Senior Project Manager | hsayani@langan.com
Hussein Sayani is a climate scientist with over 10 years of experience in climate change research, data analytics, and science communication. He received a Ph.D. in Earth and Atmospheric Science from Georgia Tech and currently holds a courtesy Research Scientist appointment at Florida State University. Hussein specializes in helping companies develop their ESG programs (strategy, ratings, and disclosure) and carbon accounting (quantifying GHG emissions, developing LCAs, and target setting).
Projects
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Digital Solutions
Geographic Information Systems
Kyle Strumfels, CHMM
Associate | kstrumfels@langan.com
Kyle leads Langan’s M&A advisory practice, which focuses on ESG and EHS due diligence matters. He has over 20 years of experience assessing environmental risk and ESG issues for multi-national transactions. Kyle and his team provide strategic support throughout the deal cycle to private equity, legal, industrial, and commercial investment clients.
Projects
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Digital Solutions
Geographic Information Systems
Leslie Wong
Senior Associate | lwong@langan.com
Leslie Wong specializes in ESG strategy/disclosure, energy efficiency, and carbon accounting. She has 30 years of experience in environmental management with a specific focus on ESG services over the past 15 years. She has assisted a range of clients from the waste services, manufacturing, and energy industries with carbon footprinting, GHG reduction strategy development and implementation, carbon credit generation, energy efficiency studies, and ESG disclosure implementation.
Projects
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Digital Solutions
Geographic Information Systems
Rory Johnston, PE, BCEE
Managing Principal | rjohnston@langan.com
With nearly 35 years of engineering experience, Rory Johnston, PE, BCEE serves as a Managing Principal and as Langan’s Director of Health & Safety. His experience includes major oil & gas, chemical, mining, aviation, pharmaceutical, and real estate development. His projects range from portfolio due diligence, environmental investigation remediation, geotechnical investigations/construction, and HSSE compliance/management to ESG and management consulting throughout the US.
Projects
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Digital Solutions
Geographic Information Systems
Click on each service to learn more
Our Team
Rory Johnston
Managing Principal
Leslie Wong
Senior Associate
Hussein Sayani
Senior Project Manager
Amy Drewing
Senior Project Manager
Chris Glenn
Associate
Gary Hacker
Senior Project Manager
Michael Patterson
Senior Project Scientist
Gary Bacon
Senior Associate
Amy Drewing
Senior Project Manager
Devesh Sinha
Associate
Rory Johnston
PE, BCEE
Managing Principal | rjohnston@langan.com
With nearly 35 years of engineering experience, Rory Johnston, PE, BCEE serves as a Managing Principal and as Langan’s Director of Health & Safety. His experience includes major oil & gas, chemical, mining, aviation, pharmaceutical, and real estate development. His projects range from portfolio due diligence, environmental investigation remediation, geotechnical investigations/construction, and HSSE compliance/management to ESG and management consulting throughout the US.
M.S., Civil Engineering, University of California
B.S., Civil Engineering, Rutgers University
B.A., Rutgers University
Professional Engineer
Board Certified Environmental Engineer
Education
Professional Registration
Leslie Wong
Senior Associate | lwong@langan.com
Leslie Wong specializes in ESG strategy/disclosure, energy efficiency, and carbon accounting. She has 30 years of experience in environmental management with a specific focus on ESG services over the past 15 years. She has assisted a range of clients from the waste services, manufacturing, and energy industries with carbon footprinting, GHG reduction strategy development and implementation, carbon credit generation, energy efficiency studies, and ESG disclosure implementation.
J.D., Law, UALR William H. Bowen School of Law
B.A., English, Hendrix College
Licensed Attorney in the State of Texas
Education
Professional Registration
Kyle Strumfels
Associate | kstrumfels@langan.com
Kyle leads Langan’s M&A advisory practice, which focuses on ESG and EHS due diligence matters. He has over 20 years of experience assessing environmental risk and ESG issues for multi-national transactions. Kyle and his team provide strategic support throughout the deal cycle to private equity, legal, industrial, and commercial investment clients.
CHMM
M.S., Environmental Policy, University of Pennsylvania
B.A., History, College of William and Mary
Executive Education in Sustainability Leadership, Harvard University
Certified Hazardous Materials Manager
Education
Professional Registration
Hussein Sayani
PhD
Senior Project Manager | hsayani@langan.com
Hussein Sayani is a climate scientist with over 10 years of experience in climate change research, data analytics, and science communication. He received a Ph.D. in Earth and Atmospheric Science from Georgia Tech and currently holds a courtesy Research Scientist appointment at Florida State University. Hussein specializes in helping companies develop their ESG programs (strategy, ratings, and disclosure) and carbon accounting (quantifying GHG emissions, developing LCAs, and target setting).
Ph.D., Earth and Atmospheric Science (focus: climatology), Georgia Institute of Technology
B.S., Earth and Atmospheric Science, Georgia Institute of Technology
Professional Engineer
Board Certified Environmental Engineer
Education
Professional Registration
Amy Drewing
CPEA, LEED AP
Senior Project Manager | adrewing@langan.com
Amy Drewing has over 18 years of environmental consulting experience specializing in ESG, mergers and acquisitions, and compliance support. She has extensive expertise in providing Phase I and Phase II Environmental Site Assessments; Environmental, Health, Safety, and Sustainability auditing; industrial hygiene; industrial health and safety program management; health and safety planning and oversight for construction, remediation, and demolition activities; and more.
B.S., Environmental Science, Business Emphasis, Southeast Missouri State University
Asbestos Inspector
Education
Professional Registration
Chris Glenn
PE, LEED GA, ENV SP
Associate | cglenn@langan.com
Chris Glenn has over 20 years of experience providing environmental engineering and sustainable development solutions for clients. He serves as Langan’s Sustainability Director, leading the implementation of Langan’s corporate sustainability program to improve the environmental and social performance of our internal operations. He assists clients with sustainable site design, reducing embodied carbon of design, GHG inventory and offset, and ESG program development.
M.S., Civil & Environmental Engineering,
Stanford University
B.S., Biological Sciences, Washington University
Professional Engineer
LEED Green Associate
Envision Sustainability Professional
Education
Professional Registration
Gary Hacker
CPEA, LEED AP
Senior Project Manager | ghacker@langan.com
Gary Hacker has 40 years of experience in the areas of environmental due diligence and environmental compliance assessments. He works with private equity, legal, industrial, and commercial investment clients to provide strategic support throughout the deal cycle. He has successfully completed portfolio due diligence projects on a global scale and has led clients to achieve the best possible outcome.
B.S., Environmental Science,
Pennsylvania State University
Certified Professional Environmental Auditor
LEED Accredited Professional
Certified ISO 140001 Lead Assessment Auditor
Education
Professional Registration
Michael Patterson
Senior Project Scientist | mpatterson@langan.com
Michael Patterson has 30 years of multi-disciplinary experience assisting clients with a wide range of ESG consulting services related to mergers, acquisitions, and divestitures. He works closely with manufacturing, oil & gas, chemical, pharmaceutical, legal, insurance, real estate, private equity, and banking clients to identify material areas of concern and compliance issues related to transactions.
B.A., Geography and Environmental Science, Bucknell University
Education
Professional Registration
Gary Bacon
PE, MBA
Senior Associate | gbacon@langan.com
Gary Bacon has managed environmental engineering, design, procurement, permitting, and compliance assurance for a broad range of industries. His experience includes regulatory applicability determinations, environmental permitting, compliance audits, air emissions inventories, licensing support of energy facilities, and implementation of EHS management information systems at public and private sector facilities throughout the US.
M.B.A., Fordham University
B.S., Chemical Engineering, Bucknell University
Professional Engineer
Education
Professional Registration
Devesh Sinha
PMP, SCJP, Lean Sensei
Associate | dsinha@langan.com
Devesh Sinha is an EHS Business Transformation Consultant with a focus on information management-based EHS process optimization. He has a strong track record of guiding private and public sector clients through the selection and implementation of technology that aligns with their strategic goals.
E.M.B.A., Arizona State University
M.S., Arizona State University
B.S., Electrical Engineering, Birla Institute of Technology
Project Management Professional
Sun Certified Java Programmer
Lean Sensei
Education
Professional Registration
Erin Hansen
PMP, PE
Senior Project Manager | ehansen@langan.com
Erin Hansen is an environmental engineer with 10 years of combined experience in ESG and air quality. She works with oil & gas, steel, and a variety of other industries, specializing in quantifying air emissions – including GHG emissions – from complex sources. Her focus areas include air permitting and regulatory compliance, process simulation, carbon accounting, and emission inventory preparation.
B.S. Environmental Engineering,
Colorado School of Mines
Professional Engineer
Education
Professional Registration
Meredith Gracey
PMP, PE
Senior Project Manager | mgracey@langan.com
Meredith Gracey delivers business and technology solutions and consulting services in Environmental, Health, Safety, and Sustainability management and environmental compliance. Her experience includes a focus on environmental management information system and ESG software selection, implementation, deployment, and maintenance. Meredith is a subject- matter expert in air quality permitting and compliance, water management, task management, and incident management.
B.S., Chemical Engineering
University of Arizona
Professional Engineer
Project Management Professional
Education
Professional Registration
ESG INTEL
...On Developing a Holistic ESG Program
New York, NY
Over the last two decades, investing guided by corporate environmental, social, and governance (ESG) principles has become a $35 trillion industry. Investors are increasingly relying on ESG disclosures and scoring to guide decision-making and stakeholders are demanding progress across ESG metrics—particularly on issues relating to climate change, diversity, and equity. And research backs up this shift toward ESG...
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ESG INTEL
...On Greenwashing
New York, NY
Media, lawmakers, and consumers are increasingly using the term “greenwashing” to criticize companies and products marketed as more environmentally beneficial than they actually are. Greenwashing is being used to describe a range of embellishments from minor cases like companies that include splashy greenhouse gas (GHG) emissions reduction stories in their ESG reports while burying the fact that their overall...
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ESG INTEL
...On Developing a Holistic ESG Program
New York, NY
Over the last two decades, investing guided by corporate environmental, social, and governance (ESG) principles has become a $35 trillion industry. Investors are increasingly relying on ESG disclosures and scoring to guide decision-making and stakeholders are demanding progress across ESG metrics—particularly on issues relating to climate change, diversity, and equity. And research backs up this shift toward ESG...
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Resources
Click each video to learn more
What is ESG?
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ESG INTEL
...On California Climate Change Disclosure Rules
On October 7, 2023, California Governor Gavin Newsom signed legislation requiring high-revenue companies (more than $1 billion per year) doing business in California to publicly report their annual scope 1, 2, and 3 greenhouse gas (GHG) emissions by 2026. The legislation, known as the Climate Corporate Data Accountability Act (SB 253), requires subject companies to report GHG emissions in accordance with the GHG Protocol and requires increasing levels of data assurance through 2030.
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ESG INTEL
Following the Securities and Exchange Commission’s (SEC) proposed rule to compel more in-depth climate change disclosure by its registrants released on April 11, 2022, the issue of when the rule would be finalized has created controversy. Predictions from regulatory commentators ranged from “never” to “late 2022” with equal gusto and very different assumptions.
...On SEC Climate Change Disclosure Rule - New Anticipated Approval Date
NEXT >
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11
ESG INTEL
...On How Climate Transparency Creates Web of Requirements
Since its release in March, the Securities and Exchange Commission’s (SEC) Climate Change Reporting Rule has dominated climate change disclosure discussions. However, the rule includes pointed deviations from California’s groundbreaking climate change disclosure legislation released in late 2023. These differences have formed one of the biggest disclosure challenges in the United States (e.g., how to align multiple disclosures to cover requirements without creating conflicts).
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ESG INTEL
On October 7, 2023, California Governor Gavin Newsom signed legislation requiring high-revenue companies (more than $1 billion per year) doing business in California to publicly report their annual scope 1, 2, and 3 greenhouse gas (GHG) emissions by 2026. The legislation, known as the Climate Corporate Data Accountability Act (SB 253), requires subject companies to report GHG emissions in accordance with the GHG Protocol and requires increasing levels of data assurance through 2030.
...On California Climate Change Disclosure Rules
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