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Board Clarifies that Claim Accrual Contains Implicit "Reasonableness" Standard

Client Alert | 1 min read | 06.07.17

In Sparton DeLeon Springs, LLC (ASBCA No. 60416, May 18, 2017), the Board denied the government’s request for reconsideration of an earlier Board decision, which had rejected the government’s claim for recoupment of alleged overpayments of direct costs as time-barred by the CDA's six-year statute of limitations (previously discussed in a blog post). In support of this reconsideration decision, and in response to the government’s argument that "the Board applied the wrong legal standard for determining whether the claim had accrued," the Board explained that it saw "no conceptual difference between the 'should have been known' standard set forth in [FAR] 33.201" and "the phrase 'reasonably should have known' recited by the government" because "the one expresses only what the other implies."

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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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