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Stay of FSS Procurement Requires Prompt Action

Client Alert | less than 1 min read | 11.09.05

In Systems Plus, Inc. v. U.S. (Oct. 27, 2005), the Court of Federal Claims held that a Federal Supply Schedule procurement for a blanket purchase agreement conducted as a commercial item buy under FAR part 12, rather than part 15, does not require that the agency provide a debriefing to a disappointed bidder. As a result, the automatic statutory stay upon a GAO protest runs only for 10 days from contract award and not also for 5 days from any discretionary debriefing in such situations.

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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....