Utilities React to Confusing Buy America Restrictions
Client Alert | 1 min read | 07.17.13
As a result of recent changes in the Moving Ahead for Progress in the 21st Century Act (MAP-21) and how those changes are being implemented by federal and state agencies, utilities are now facing expanded application of two longstanding, but different, Buy America provisions of the Federal Highway Administration and the Federal Transit Administration on the use of foreign iron, steel, and manufactured goods on relocation agreements with state agencies. Utility industry representatives have objected and requested that DOT clarify the requirements, establish consistent, DOT-wide Buy America provisions, and implement a transition period during which the restrictions would not apply, and CALTRANS, a California state agency, has sought a waiver for a significant project, prompting a spectrum of thoughtful comments.
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Client Alert | 7 min read | 12.17.25
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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