California Air Resources Board Revisits Advanced Clean Fleets Rule Through Formation of Truck Regulation Advisory Committee

In April 2023, the California Air Resources Board (CARB) passed its Advanced Clean Fleets (ACF) rule, which will require California medium- and heavy-duty truck and bus fleet owners with over $50 million in annual revenue to transition to zero emission vehicles through a phaseout of their existing internal combustion engine–powered vehicles by 2045. On July 26, 2023, while the ACF rule was pending with the California Office of Administrative Law for a final determination prior to release, CARB withdrew the regulatory package with the intention of resubmitting it “at a subsequent date.” CARB is now forming a Truck Regulation Advisory Committee and, on August 22, 2023, will host a public meeting to discuss and solicit feedback on future efforts to implement the ACF rule. Instructions for participation in this public meeting can be found here.

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U.S. EPA Memo Offers Direction on Lithium Battery Recycling—Essential to the Future Supply Chain for Battery Electric Vehicles

Lithium-ion batteries are commonly used in a wide variety of applications, from medical devices to laptops — and now, increasingly, in electric vehicles (EVs). With the market for personal and commercial EVs growing, it is essential for U.S. manufacturers to have a secure, reliable supply chain of the critical minerals needed to produce EV batteries, including lithium, cobalt, nickel, and copper. Indeed, a recent study highlights the growing demand for these minerals — and the challenges the U.S. faces to meet this demand from mined sources.

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Joint Office of Energy and Transportation Names Electric Vehicle Working Group Members

On August 3, 2023, the Joint Office of Energy and Transportation — created through the Bipartisan Infrastructure Law to facilitate collaboration between the U.S. Departments of Energy (DOE) and Transportation (DOT) — officially announced the members of its Electric Vehicle (EV) Working Group, an independent advisory board. Parties interested in the growth of EVs in the United States should take note of the group, which will coordinate and consult on the development, adoption, and integration of EVs into the transportation and energy systems of the United States.

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U.S. Wildlife Agencies Propose Rules to Reinstate Longstanding Endangered Species Act Regulations

On June 22, the U.S. Fish and Wildlife Service and National Oceanic and Atmospheric Administration published a series of proposed rules pursuant to the Endangered Species Act (the Act), seeking to clarify or reverse implementing regulations issued in 2019 during the Trump administration. The agencies jointly proposed two rules—one revising Section 7 regulations, related to interagency consultations, and a second revising Section 4 regulations, related to listing decisions and critical habitat designations. The Fish and Wildlife Service independently proposed a third rule to reinstate the general application of “blanket rule” options for protecting newly listed threatened species pursuant to Section 4(d) of the Act.

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White House Announces New ‘Ocean Justice Strategy’

On June 7, 2023, the White House Council on Environmental Quality (CEQ) published a request for information (RFI) in the Federal Register seeking input on its planned Ocean Justice Strategy (the “Strategy”). The RFI describes the Strategy as an effort to integrate environmental justice principles into ocean-related activities of the federal government. The Strategy could have wide-ranging impacts on the development of ocean energy resources.

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U.S. Department of Energy Releases Critical Materials Assessment for Public Comment

On May 30, 2023, the U.S. Department of Energy (DOE) issued for public comment its draft Critical Materials Assessment. In the draft assessment, DOE characterized 22 different materials as critical, near critical, or noncritical to the nation’s energy needs based on the importance of those materials to energy applications and supply risk. DOE uses its Critical Materials Assessment — which it anticipates updating every three years — to “prioritize research and development efforts to meet the nation’s energy needs while reducing reliance on materials with high supply risk.” DOE explained that inclusion of a material on the critical materials for energy list may inform critical minerals Research Development, Demonstration, and Commercial Application (RDD&CA) Program priorities and eligibility for the Inflation Reduction Act Qualifying Advanced Energy Project Section 48C tax credits.

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U.S. EPA Opens Public Comment on Funding for Zero-Emission Vehicles and Charging Infrastructure Under Inflation Reduction Act

The U.S. Environmental Protection Agency (EPA) issued, on May 5, 2023, a request for information seeking input on the availability of zero-emission technologies in the heavy-duty vehicle and port sectors toward establishing funding programs under the Inflation Reduction Act (IRA). EPA requests comment from manufacturers, distributors, installers, fleet operators, and port operators about their products and experience with zero-emission technologies.

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EPA Proposes Granting Louisiana Primacy Over Carbon Sequestration Well Program

The U.S. Environmental Protection Agency (EPA) proposed to approve Louisiana’s request for control over the permitting of carbon sequestration wells in the state. EPA’s approval would provide Louisiana authority under the Safe Drinking Water Act (SDWA) Underground Injection Control (UIC) program to administer a “Class VI” injection well program for the geologic sequestration of carbon dioxide, following similar such approvals for North Dakota and Wyoming. Stakeholders should take note of this proposed action because EPA approval of Louisiana’s program could advance carbon capture and sequestration (CCS) projects stymied by the backlog of permit applications pending before the EPA.

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Meet the Team

<a target=‘_blank’ href="https://www.sidley.com/en/people/v/vrielink-cliff-w">Cliff W. Vrielink</a>

Cliff W. Vrielink

Houston
<a target=‘_blank’ href="https://www.sidley.com/en/people/i/irvin-kenneth-w">Kenneth W. Irvin</a>

Kenneth W. Irvin

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/higgins-tara">Tara Higgins</a>

Tara Higgins

New York
<a target=‘_blank’ href="https://www.sidley.com/en/people/h/hamner-iii-herschel-t">Herschel T. Hamner III</a>

Herschel T. Hamner III

Houston
<a target=‘_blank’ href="https://www.sidley.com/en/people/m/macarthur-james">James MacArthur</a>

James MacArthur

London
<a target=‘_blank’ href="https://www.sidley.com/en/people/a/atkins-raymond-a">Raymond A. Atkins Ph.D.</a>

Raymond A. Atkins Ph.D.

Washington, D.C.
<a target=‘_blank’ href="https://www.sidley.com/en/people/l/lewis-kevin-p">Kevin P. Lewis</a>

Kevin P. Lewis

Houston
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