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Attention To Small Business Subcontracting Plan Is No Small Matter

Client Alert | less than 1 min read | 11.07.05

In Coastal Maritime Stevedoring, LLC (Sept. 22, 2005 http://www.gao.gov/decisions/bidpro/296627.pdf), GAO found unreasonable the Source Selection Authority's decision to change the awardee's rating from unsatisfactory to satisfactory under the socioeconomic commitment factor when the awardee's small business subcontracting plan failed to address required elements of FAR 19.704 and otherwise neglected to comply with the solicitation's required objective for subcontracting to small businesses 10% of the total contract value. GAO also determined that the agency's price/technical tradeoff was flawed because it failed to take into account advantages in the protester's proposal that translated into quantifiable cost savings to the government.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....

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