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The Sun Has Not Set On Protests Of Civilian Agency Task Orders

Client Alert | 1 min read | 06.14.11

In Technatomy Corp. (June 14, 2011), GAO ruled that the sunset provision contained in the 2008 amendments to the Federal Acquisition Streamlining Act ("FASA") for GAO's civilian task order protest jurisdiction applied not only to the provisions granting GAO exclusive jurisdiction over protests of task order awards in excess of $10 million, but to the entirety of subsection 41 U.S.C.§ 253j(e), and, therefore, GAO's jurisdiction over protests of task or delivery orders essentially reverted to the jurisdiction that previously existed under CICA (pre-FASA), under which there is no jurisdictional distinction between protests of awards of contracts and of task orders. The net effect is that any task order award of any value pursuant to a civilian agency contract is subject to the protest jurisdiction of GAO and possibly of the Court of Federal Claims, to the extent that court agrees with GAO's ruling.

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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....