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Only Significant OCIs Require Mitigation

Client Alert | less than 1 min read | 08.18.10

On August 5, 2010, the Federal Circuit in PAI Corp. v. U.S. affirmed the lower court's determination that contracting officers have an obligation to mitigate "significant" OCIs, but that the FAR does not require "mitigation of other types of conflicts, such as apparent or potential non-significant conflicts."  The Federal Circuit also held that contracting officers have broad discretion to determine whether an OCI is "significant" and that FAR 9.504(a) does not require that contracting officers document their initial identification and evaluation of potential conflicts.

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Client Alert | 4 min read | 05.01.26

Federal Court Blocks Trump Administration Policies Restricting Wind and Solar Permitting

A coalition of regional clean energy trade associations — including RENEW Northeast, Alliance for Clean Energy New York, Southern Renewable Energy Association, and Interwest Energy Alliance — along with the Green Energy Consumers Alliance (GECA), filed suit in December 2025 against the Department of the Interior (DOI), the Bureau of Land Management, the Bureau of Ocean Energy Management, the U.S. Fish and Wildlife Service (USFWS), and the Army Corps of Engineers. The complaint alleged that five agency actions, issued in response to a series of executive orders and presidential memoranda beginning on January 20, 2025, violated the Administrative Procedure Act (APA) by arbitrarily halting or restricting federal permitting for wind and solar energy projects. Plaintiffs sought a preliminary injunction to halt enforcement of these policies while the litigation proceeds. See Renew Northeast, et al. v. U.S. Dep’t of Interior, et al., No. 25-cv-13961-DJC,  (D. Mass. Apr. 21, 2026) ECF Dkt. 89....