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FEMA to Release New Emergency Management Priorities and Allocation System to Govern FEMA DPA Title I Activities

Client Alert | 1 min read | 05.12.20

On May 13, 2020, the Federal Emergency Management Agency (FEMA) will publish an interim final rule establishing the Emergency Management Priorities and Allocation System (EMPAS) pursuant to Title I of the Defense Production Act (DPA). As drafted, EMPAS will apply beyond the current COVID-19 context and will become part of the Federal Priority and Allocations System (which includes, for example, the Defense Priorities and Allocation System (DPAS) and the Health Resources Priority and Allocations System (HRPAS)). Although largely similar to the DPAS and HRPAS, EMPAS also provides express authorization to issue rated orders to facilitate sales of health and medical resources to third parties while simultaneously rejecting any government financial liability for such orders (44 C.F.R. § 333.12(c) and 333.19). EMPAS is effective immediately upon publication, and comments on the interim final rule will be accepted through June 12, 2020.

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Client Alert | 5 min read | 12.02.25

CARB Delays Enforcement of California’s Climate-Related Financial Risk Report Law (SB 261) and Issues New Guidance on Climate Disclosure Requirements in SB 261 and SB 253

As we have reported previously, California has enacted a pair of climate-related reporting laws that apply to large entities doing business in California (SB 253 and SB 261, as modified by SB 219). This alert provides an update on only the most recent events; please see previous alerts for a broader overview of the laws’ requirements....