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GSA Seeks Input on Acquisition Regulations, Including the Alphabet Soup of TDR, PRC, and CSP

Client Alert | 1 min read | 05.30.17

In accordance with President Trump’s continuing mandate to streamline federal regulations, GSA is seeking input on its acquisition regulations, policies, and guidance that may be appropriate for repeal, replacement, or modification. GSA is particularly interested in comments on less frequently addressed areas such as evergreen contracting, price adjustments, catalogs, utilities, construction, and facilities. However, GSA is also welcoming comments on bigger ticket items such as the recent Transactional Data Reporting (TDR) rule, the Price Reduction Clause (PRC), and the Commercial Sales Practice (CSP) format. Comments are due in late July, and will provide interested parties an invaluable opportunity to address a broad swath of GSA’s existing policies and practices. Indeed, with recent indications that compliance with TDR requirements may soon become optional, this request for input appears very well timed to assist GSA in making important decisions for the Schedule program going forward.

Insights

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....