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Akin Gump

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What’s Next for SB 253 and SB 261? Ninth Circuit Oral Argument Recap

On December 1, 2025, the New York Department of Environmental Conservation (NYDEC) finalized regulations for its greenhouse gas (GHG) emissions reporting program under the Climate Leadership and Community Protection Act (CLCPA).1 These rules establish mandatory annual GHG reporting requirements for certain facilities and suppliers beginning June 1, 2027, with earlier compliance milestones for Large Emission Sources and anaerobic digestion, liquid waste storage and certain solid waste landfill operators taking effect in late 2026. We previously wrote about the draft regulations here. The regulations follow an October 2025 order from a New York state court requiring NYDEC to promulgate regulations after the agency missed the January 1, 2024 statutory deadline.