REFINER Act

H.R. 1346, Nationwide Consumer and Fuel Retailer Choice Act of 2025; H.R. 3109, REFINER Act; The Agricultural Act of 2026; Title XII, Miscellaneous, Subtitle E, Sec. 12501, Year-Round E15 and RFS Reform; Renewable Fuels Standard RVO Annual Rule 2026 and 2027; FTZ designation application; Executive actions related to emergency RVP waivers; Extension of Standard Futures Contracts to 24/7 Trading and Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities; S.J.Res. 205 and H.J. Res 214 related to California standards for off road engines; S.J.Res. 206 and H.J.Res. 211 related to California standards for vehicles; S.J.Res. 207 and H. J.Res. 205 related to California standards for vehicles; S.J.Res. 208 and H.J.Res. 212 related to California standards for vehicles; S.J. Res 209 and H.J. Res 210 related to California standards for at berth vessels; S.J. Res 210 and H.J.Res. 213 related to California standards for commercial harbor craft.

Client expense: $1,280,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, White House Office

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act; California Clean Air Act Waivers; Corporate Average Fuel Economy Standards; H.R. 8330 / S. 434

Client expense: $1,520,000 · Firm income: Not reported

H.R. 77, Midnight Rules Relief Act H.R. 755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1047, GRID Power Act H.R. 1687, Committing Leases for Energy Access Now (CLEAN) Act H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3015, National Coal Council Reestablishment Act H.R. 3062, Promoting Cross-Border Energy Infrastructure Act H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3616, Reliable Power Act H.R. 3617, the Securing America's Critical Minerals Supply Act H.R. 3628, State Planning for Reliability and Affordability Act H.R. 3632, Power Plant Reliability Act of 2025 H.R. 3638, Electric Supply Chain Act H.R. 3699, Energy Choice Act H.R. 4754, Department of Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 5631, Geothermal Energy Advancement Act H.R. 6336, Fair Allocation of Interstate Rates (FAIR) Act H.R. 7257, Securing Community Upgrades for a Resilient Grid (SECURE Grid) Act H.R. 7258, Energy Emergency Leadership Act H.R. 7266, Rural and Municipal Utility Cybersecurity Act H.R. 7305, Energy Threat Analysis Center Act of 2026 H.R. 8477, American Energy Dominance Act H.R. 8790, Next Generation Geothermal Research and Development Act S. 1071, National Defense Authorization Act for Fiscal Year 2026 S. 3947, Reconductoring Existing Wires for Infrastructure Reliability and Expansion (REWIRE) Act of 2026 H.J. Res. 35/S.J. Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar to H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J. Res. 91/S.J. Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con. Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Energy and Water appropriations bill for fiscal year 2026 Potential legislation relating to industry- and consumer-facing energy efficiency tax incentives Beginning of Construction Requirements for Purposes of the Termination of Clean Electricity Production Credits and Clean Electricity Investment Credits for Applicable Wind and Solar Facilities (IRS Notice 2025-42, August 20, 2025) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Wind Turbines and Their Parts and Components (90 Fed. Reg. 41,380-41,381, August 25, 2025) Proposed Rule, NHTSA "Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule III," revising CAFE standards for Model Years (MY) 2022-2031, (90 Fed. Reg. 56,438-56,656, December 5, 2025) Notice Inviting Comments, Interconnection of Large Loads to the Interstate Transmission System, issued in Federal Energy Regulatory Commission Docket No. RM26-4-000 (October 27, 2025) Various issues relating to regulatory permit streamlining, reform of National Environmental Policy Act (NEPA), and related judicial reform; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally; energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of the One Big Beautiful Bill Act, (P.L. 119-21); funding for the Clean Water and Drinking Water State Revolving Funds, the Water Infrastructure Finance and Innovation Act; cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification; potential Administration or agency actions affecting bulk power system supply chains, including tariffs, other import restrictions, and tax policy and related implementation; Administration and agency actions relating to renewable generation resources; energy efficiency, generally, and its benefit as a tool to address electric demand growth; Department of Energy activities affecting the electric grid, including anticipated Grid Executive Order; implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters (P.L.119-6)

Renewable Fuel Standard (RFS), S 593/HR 1346, S 2742/HR 5636, fuel policy; HR 7567 (Farm Bill, specifically issues related to the RFS and E15); Impact of crude supply regulations on refiners, crude supply in general; H.R. 1346 - The Nationwide Consumer and Fuel Retailer Choice Act; H.R. 3109 - REFINER Act; 40 CFR Part 80, Subpart M- Energy Policy Act of 2005 and Set 2 Rulemaking; Department of Homeland Security Directive Under Authority of 46 U.S.C. 501; Implementation Notice CSMS #68096516.

Client expense: $200,000 · Firm income: Not reported

Government targets: Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE

H.R. 1346 - The Nationwide Consumer and Fuel Retailer Choice Act; H.R. 3109 - REFINER Act; H.R. 7384 - Preventing Mass Casualties from Release of Hydrofluoric Acid at Refineries Act; Biofuel Policy Task Force; 40 CFR Part 80, Subpart M- Energy Policy Act of 2005 and Set 2 Rulemaking; H.R. 7567- Farm, Food, and National Security Act of 2027; Treasury Regulation Code Section 45Z; Department of Homeland Security Directive Under Authority of 46 U.S.C. 501; Implementation Notice CSMS #68096516.

Client expense: $200,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

H.R. 1346, Nationwide Consumer and Fuel Retailer Choice Act of 2025; H.R. 3109, REFINER Act; S. 3759, Security America's Fuels Act; H.R. 6518, Securing Americas Fuels Act; *draft* legislation supporting year around E15 and Small Refinery Exemption reform; Renewable Fuels Standard RVO Annual Rule 2026 and 2027; FTZ designation application; Executive actions related to emergency RVP waivers; Extension of Standard Futures Contracts to 24/7 Trading and Perpetual Contracts Referencing Physically Delivered or Storable Energy Commodities

Client expense: $1,320,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, White House Office

H.R. 1949 and H.R. 3109, Kern County Natural Resources Development Zone

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

H.R. 77, Midnight Rules Relief Act H.R. 755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1047, GRID Power Act H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3015, National Coal Council Reestablishment Act H.R. 3062, Promoting Cross-Border Energy Infrastructure Act H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3616, Reliable Power Act H.R. 3628, State Planning for Reliability and Affordability Act H.R. 3632, Power Plant Reliability Act of 2025 H.R. 3638, Electric Supply Chain Act H.R. 3699, Energy Choice Act H.R. 4754, Department of Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 6336, Fair Allocation of Interstate Rates (FAIR) Act H.R. 7257, Securing Community Upgrades for a Resilient Grid (SECURE Grid) Act H.R. 7258, Energy Emergency Leadership Act H.R. 7266, Rural and Municipal Utility Cybersecurity Act H.R. 7305, Energy Threat Analysis Center Act of 2026 S. 1071, National Defense Authorization Act for Fiscal Year 2026 S. 3947, Reconductoring Existing Wires for Infrastructure Reliability and Expansion (REWIRE) Act of 2026 H.J. Res. 35/S.J. Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1085, Researching Efficient Federal Improvements for Necessary Energy Refining (REFINER) Act Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar to H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3062, Promoting Cross-Border Energy Infrastructure Act Potential legislation similar to H.R. 3617, Securing Americas Critical Minerals Supply Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J. Res. 91/S.J. Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con. Res.14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Energy and Water appropriations bill for fiscal year 2026 Beginning of Construction Requirements for Purposes of the Termination of Clean Electricity Production Credits and Clean Electricity Investment Credits for Applicable Wind and Solar Facilities (IRS Notice 2025-42, August 20, 2025) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Wind Turbines and Their Parts and Components (90 Fed. Reg. 41,380-41,381, August 25, 2025) Proposed Rule, NHTSA "Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule III," revising CAFE standards for Model Years (MY) 2022-2031, (90 Fed. Reg. 56,438-56,656, December 5, 2025) Notice Inviting Comments, Interconnection of Large Loads to the Interstate Transmission System, issued in Federal Energy Regulatory Commission Docket No. RM26-4-000 (October 27, 2025) Various issues relating to regulatory permit streamlining, reform of National Environmental Policy Act (NEPA), and related judicial reform; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; establishing a durable program for managing used nuclear fuel; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally; energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters (P.L.119-6); implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions (P.L. 119-2); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers (P.L. 119-9); funding for the Clean Water and Drinking Water State Revolving Funds, the Water Infrastructure Finance and Innovation Act; proposed risk management consultation on PFAS; implementation of the EU Methane Regulation; cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification; potential Administration or agency actions affecting bulk power system supply chains, including tariffs, other import restrictions, and tax policy and related implementation; Administration and agency actions relating to renewable generation resources; energy efficiency, generally, and its benefit as a tool to address electric demand growth; Department of Energy activities affecting the electric grid, including anticipated Grid Executive Order

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act; California Clean Air Act Waivers; Corporate Average Fuel Economy Standards;

Client expense: $1,160,000 · Firm income: Not reported

H.R. 1949 and H.R. 3109, Kern County Natural Resources Development Zone

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

H.R. 77, Midnight Rules Relief Act H.R. 755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1047, GRID Power Act H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3015, National Coal Council Reestablishment Act H.R. 3062, Promoting Cross-Border Energy Infrastructure Act H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3616, Reliable Power Act H.R. 3628, State Planning for Reliability and Affordability Act H.R. 3632, Power Plant Reliability Act of 2025 H.R. 3638, Electric Supply Chain Act H.R. 3699, Energy Choice Act H.R. 4754, Department of Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 6336, Fair Allocation of Interstate Rates (FAIR) Act H.R. 7257, Securing Community Upgrades for a Resilient Grid (SECURE Grid) Act H.R. 7258, Energy Emergency Leadership Act H.R. 7266, Rural and Municipal Utility Cybersecurity Act H.R. 7305, Energy Threat Analysis Center Act of 2026 S. 1071, National Defense Authorization Act for Fiscal Year 2026 S. 3947, Reconductoring Existing Wires for Infrastructure Reliability and Expansion (REWIRE) Act of 2026 H.J. Res. 35/S.J. Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1085, Researching Efficient Federal Improvements for Necessary Energy Refining (REFINER) Act Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar to H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3062, Promoting Cross-Border Energy Infrastructure Act Potential legislation similar to H.R. 3617, Securing Americas Critical Minerals Supply Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J. Res. 91/S.J. Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con. Res.14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Energy and Water appropriations bill for fiscal year 2026 Beginning of Construction Requirements for Purposes of the Termination of Clean Electricity Production Credits and Clean Electricity Investment Credits for Applicable Wind and Solar Facilities (IRS Notice 2025-42, August 20, 2025) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Wind Turbines and Their Parts and Components (90 Fed. Reg. 41,380-41,381, August 25, 2025) Proposed Rule, NHTSA "Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule III," revising CAFE standards for Model Years (MY) 2022-2031, (90 Fed. Reg. 56,438-56,656, December 5, 2025) Notice Inviting Comments, Interconnection of Large Loads to the Interstate Transmission System, issued in Federal Energy Regulatory Commission Docket No. RM26-4-000 (October 27, 2025) Various issues relating to regulatory permit streamlining, reform of National Environmental Policy Act (NEPA), and related judicial reform; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; establishing a durable program for managing used nuclear fuel; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally; energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters (P.L.119-6); implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions (P.L. 119-2); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); implementation of providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerators, Freezers, and Refrigerator-Freezers (P.L. 119-9); funding for the Clean Water and Drinking Water State Revolving Funds, the Water Infrastructure Finance and Innovation Act; proposed risk management consultation on PFAS; implementation of the EU Methane Regulation; cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification; potential Administration or agency actions affecting bulk power system supply chains, including tariffs, other import restrictions, and tax policy and related implementation; Administration and agency actions relating to renewable generation resources; energy efficiency, generally, and its benefit as a tool to address electric demand growth; Department of Energy activities affecting the electric grid, including anticipated Grid Executive Order

*draft* legislation supporting year around E15 and Small Refinery Exemption reform; H.R. 7148 - Consolidated Appropriations Act, 2026 - Amendment #6; Renewable Fuels Standard RVO Annual Rule 2026 and 2027; Issues pertaining to EPA potentially granting small refinery exemptions; Issues arising from the Midwest governors petition to remove the 1-psi waiver and the related EPA rulemaking; FTZ designation application; H.R. 3109, REFINER Act; Executive actions related to emergency RVP waivers; S. 3759 and H.R. 6518, Securing Americas Fuels Act

Client expense: $1,320,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, White House Office

H.R. 161 New Source Review Permitting Improvement Act; EPA RFS Set 2 Proposed Rule; Sustainable Aviation Fuel; Vehicle Emissions; Fuel Prices and Petroleum Markets; H.R. 5636, S. 2742 Protect Consumers from Reallocation Costs Act of 2025; H.R. 5301 / S. 2975 Pipeline Safety Reauthorization; H.R. 1346 / S.593 To Amend the Clean Air Act with respect to the ethanol waiver; H.R. 3898 Promoting Efficient Reviews for Modern Infrastructure Today Act (PERMIT); H.R. 4776 ; Standardizing permitting and expediting economic development Act (SPEED); H.R. 6398 Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act; H.R. 6373 Air Permitting Improvements to Protect National Security Act; H.R. 4218 Clean Air and Economic Advancement Reform (CLEAR) Act; H.R. 6409 Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) Act; H.R. 3109 Refiner Act; H.R. 3699 Energy Choice Act

Client expense: $1,600,000 · Firm income: Not reported

H.R.1949 Unlocking our Domestic LNG Potential Act of 2025 H.R. 3109 REFINER Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES

SA #3397 to S. 2296, the National Defense Authorization FY 2026; H.R. 1346, S. 593, Nationwide Consumer and Fuel Retailer Choice Act of 2025; *draft legislation supporting year around E15 and Small Refinery Exemption reform; Renewable Fuels Standard RVO Annual Rule 2026 and 2027; Issues pertaining to EPA potentially granting small refinery exemptions; Issues arising from the Midwest governors petition to remove the 1-psi waiver and the related EPA rulemaking; FTZ designation application; H.R. 3109, REFINER Act

Client expense: $3,760,000 · Firm income: Not reported

Government targets: Agriculture, Dept of (USDA), Commerce, Dept of (DOC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Natl Economic Council (NEC), SENATE, White House Office

H.R. 77, Midnight Rules Relief Act H.R. 755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1047, GRID Power Act H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3015, National Coal Council Reestablishment Act H.R. 3062, Promoting Cross-Border Energy Infrastructure Act H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3616, Reliable Power Act H.R. 3628, State Planning for Reliability and Affordability Act H.R. 3632, Power Plant Reliability Act of 2025 H.R. 3638, Electric Supply Chain Act H.R. 3699, Energy Choice Act H.R. 4754, Department of Interior, Environment, and Related Agencies Appropriations Act, 2026 H.R. 6336, Fair Allocation of Interstate Rates (FAIR) Act S. 1071, National Defense Authorization Act for Fiscal Year 2026 H.J.Res. 20/S.J.Res. 4, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters. H.J.Res. 35/S.J.Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" H.J.Res. 75, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to "Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerator Freezers, and Refrigerator-Freezers" Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1085, Researching Efficient Federal Improvements for Necessary Energy Refining (REFINER) Act Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3617, Securing Americas Critical Minerals Supply Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J.Res. 91/S.J.Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con.Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Energy and Water appropriations bill for fiscal year 2026 Beginning of Construction Requirements for Purposes of the Termination of Clean Electricity Production Credits and Clean Electricity Investment Credits for Applicable Wind and Solar Facilities (IRS Notice 2025-42, August 20, 2025) Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Wind Turbines and Their Parts and Components (90 Fed. Reg. 41,380-41,381, August 25, 2025) Proposed Rule, NHTSA "Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule III," revising CAFE standards for Model Years (MY) 2022-2031, (90 Fed. Reg. 56,438-56,656, December 5, 2025) Notice Inviting Comments, Interconnection of Large Loads to the Interstate Transmission System, issued in Federal Energy Regulatory Commission Docket No. RM26-4-000 (October 27, 2025) Reconsideration of the Greenhouse Gas Reporting Program, (90 Fed. Reg. 44,591-44,618, September 16, 2025) Various issues relating to regulatory permit streamlining, reform of National Environmental Policy Act (NEPA), and related judicial reform; social cost of carbon in cost-benefit analyses underlying federal regulations; Keystone XL environmental assessment; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; establishing a durable program for managing used nuclear fuel; nuclear fuel storage at Yucca Mountain; funding for the Advanced Research Projects Agency-Energy (ARPA-E) program; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally; energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of the Natural Gas Act (P.L. 75-688); development of solar energy; development of water power; implementation of the Advanced Nuclear Fuel Availability Program, as modified by the Nuclear Fuel Security Act of 2023 (P.L. No. 118-31); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); continuation of the percentage depletion tax deduction; preservation of the Clean Hydrogen Production Tax Credit regulations under section 45V (45V); funding for the Clean Water and Drinking Water State Revolving Funds, the Water Infrastructure Finance and Innovation Act; proposed risk management consultation on PFAS; implementation of the EU Methane Regulation; cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification (P.L. 117-169); potential Administration or agency actions affecting bulk power system supply chains, including tariffs, other import restrictions, and tax policy and related implementation; Administration and agency actions relating to renewable generation resources; energy efficiency, generally; Department of Energy activities affecting the electric grid, including anticipated Grid Executive Order

H.R. 1, One Big Beautiful Bill Act H.R. 77, Midnight Rules Relief Act H.R. 755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1047, GRID Power Act H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3015, National Coal Council Reestablishment Act H.R. 3062, the Promoting Cross-Border Energy Infrastructure Act H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3632, Power Plant Reliability Act of 2025 H.R. 4754, Department of Interior, Environment, and Related Agencies Appropriations Act, 2026 H.J.Res. 20/S.J.Res. 4, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters. H.J.Res. 35/S.J. Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" H.J.Res. 75, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to "Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerator Freezers, and Refrigerator-Freezers" Draft legislation titled Small Business Energy Loan Enhancement Act Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1085, Researching Efficient Federal Improvements for Necessary Energy Refining (REFINER) Act Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3062, Promoting Cross-Border Energy Infrastructure Act Potential legislation similar to H.R. 3143, State Planning for Reliability and Affordability Act Potential legislation similar to H.R. 3616, Reliable Power Act Potential legislation similar to H.R. 3617, Securing Americas Critical Minerals Supply Act Potential legislation similar to H.R. 3638, Electric Supply Chain Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J.Res. 91/S.J.Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con.Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Nomination of Preston "Wells" Griffith III to be Under Secretary of Energy Beginning of Construction Requirements for Purposes of the Termination of Clean Electricity Production Credits and Clean Electricity Investment Credits for Applicable Wind and Solar Facilities (IRS Notice 2025-42, August 20, 2025) Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Wind Turbines and Their Parts and Components (90 Fed. Reg. 41,380-41,381, August 25, 2025) Various issues relating to regulatory permit streamlining, reform of National Environmental Policy Act (NEPA), and related judicial reform; social cost of carbon in cost-benefit analyses underlying federal regulations; Keystone XL environmental assessment; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; establishing a durable program for managing used nuclear fuel; nuclear fuel storage at Yucca Mountain; funding for the Advanced Research Projects Agency-Energy (ARPA-E) program; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally; energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of the Natural Gas Act (P.L. 75-688); development of solar energy; development of water power; implementation of the Advanced Nuclear Fuel Availability Program, as modified by the Nuclear Fuel Security Act of 2023 (P.L. No. 118-31); implementation of the One Big Beautiful Bill Act, (P.L. 119-21); continuation of the percentage depletion tax deduction; preservation of the Clean Hydrogen Production Tax Credit regulations under section 45V (45V); funding for the Clean Water and Drinking Water State Revolving Funds, the Water Infrastructure Finance and Innovation Act; cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification; potential Administration or agency actions affecting bulk power system supply chains, including tariffs, other import restrictions, and tax policy and related implementation; Administration and agency actions relating to renewable generation resources; energy efficiency, generally; Department of Energy activities affecting the electric grid, including anticipated Grid Executive Order

H.R. 1, Reconciliation H.R. 3616, Reliable Power Act (Rep. Balderson) H.R. 1047, Guaranteeing Reliability through the Interconnection of Dispatchable Power (GRID Power) Act (Rep. Balderson) H.R. 3632, Power Plant Reliability Act of 2025 (Rep. Griffith) H.R. 3617, Securing Americas Critical Minerals Supply Act (Rep. James) H.R. 3062, Promoting Cross-border Energy Infrastructure Act (Rep. Fedorchak) The Endangerment Finding (EPA implemented through the Clean Air Act) Outreach to offices regarding the Clean Energy Tax Credits contemplated in the reconciliation bill Data Centers and Load Growth Implications on the Electrical Grid Environmental Impacts of Bitcoin and Digital Currency Procurement S.919 A. Donald McEachin Environmental Justice For All Act S. 1475 Clean Cloud Act S. 394 GENIUS Act Energy Democracy in Puerto Rico Environmental Justice Community Block Grants HR 3015, National Coal Council Reestablishment Act (Rep. Rulli) HR 3109, REFINER Act (Rep. Latta) H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 (Rep. Pfluger) H.R. 381, LNG Public Interest Determination Act (Rep. Casten) H.R. 2177, Tradeable Energy Performance Standards Act (Rep. Casten) FERC GHG & EJ Act (Rep. Carsten - no bill # yet) Surface Transportation Reauthorization Bill End Polluter Welfare Act (Sen. Sanders/Rep. Omar - no bill # yet) Pipeline Accountability, Safety, and Environmental Standards Act (Sen. Markey - no bill # yet) S. 789 Critical Minerals Security Act S. 598 Unearth Innovation Act S. 1463/H.R. 2969 Finding ORE Act H.R. 3617, Securing Americas Critical Minerals Supply Act (Rep. James) TSCA Reauthorization

Client expense: $179,616 · Firm income: Not reported

H.R. 1, One Big Beautiful Bill Act H.R. 77, Midnight Rules Relief Act H.R.755/S. 714, Critical Mineral Consistency Act of 2025 H.R. 1949, Unlocking our Domestic LNG Potential Act of 2025 H.R. 2986, Expediting Generator Interconnection Procedures Act of 2025 H.R. 3109, Researching Efficient Federal Improvements for Necessary Energy Refining Act (REFINER Act) H.R. 3632, Power Plant Reliability Act of 2025 H.J.Res. 20/S.J.Res. 4, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Department of Energy relating to Energy Conservation Program: Energy Conservation Standards for Consumer Gas-fired Instantaneous Water Heaters H.J.Res. 35/S.J. Res. 12, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to "Waste Emissions Charge for Petroleum and Natural Gas Systems: Procedures for Facilitating Compliance, Including Netting and Exemptions" H.J.Res. 75, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Office of Energy Efficiency and Renewable Energy, Department of Energy relating to "Energy Conservation Program: Energy Conservation Standards for Commercial Refrigerator Freezers, and Refrigerator-Freezers" Draft legislation titled Small Business Energy Loan Enhancement Act Draft legislation to amend the Energy Policy and Conservation Act to modify standards for water heaters, furnaces, boilers, and kitchen cooktops, ranges, and ovens, and for other purposes Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Draft legislation titled Reliability Protection for States Act Draft legislation titled Energy Refining Act (REFINER Act) Draft legislation titled ePermit Act to build out agency electronic permitting system Potential legislation similar to H.R. 1047, GRID Power Act Potential legislation similar to H.R. 1070, To amend the Solid Waste Disposal Act to provide the owner or operator of a critical energy resource facility an interim permit under subtitle C that is subject to final approval by the Administrator of the Environmental Protection Agency, and for other purposes Potential legislation similar to H.R. 1085, Researching Efficient Federal Improvements for Necessary Energy Refining (REFINER) Act Potential legislation similar to H.R. 1140, To authorize the Administrator of the Environmental Protection Agency to waive application of certain requirements with respect to processing and refining a critical energy resource at a critical energy resource facility, and for other purposes Potential legislation similar to H.R. 1152, Water Quality Certification and Energy Projects Improvement Act of 2023 Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar H.R. 1577, Building United States Infrastructure through Limited Delays and Efficient Reviews (BUILDER) Act of 2023 Potential legislation similar to H.R. 2617, Consolidated Appropriations Act, 2023 Potential legislation similar to H.R. 2635/S. 3808, Restoring Offshore Wind Opportunities Act Potential legislation similar to H.R. 3015, National Coal Council Reestablishment Act Potential legislation similar to H.R. 3062, Promoting Cross-Border Energy Infrastructure Act Potential legislation similar to H.R. 3143, State Planning for Reliability and Affordability Act Potential legislation similar to H.R. 3616, Reliable Power Act Potential legislation similar to H.R. 3617, Securing Americas Critical Minerals Supply Act Potential legislation similar to H.R. 3638, Electric Supply Chain Act Potential legislation similar to H.R. 3657, Hydropower Relicensing Transparency Act Potential legislation similar to H.R. 3668, Improving Interagency Coordination for Review of Natural Gas Pipelines Act Potential legislation similar to H.R. 5551/S. 2827, Building Integrated Grids With Inter-Regional Energy Supply (BIG WIRES) Act Potential legislation similar to H.R. 6129, Studying NEPAs Impact on Projects Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7688, Consumer Fuel Price Gouging Prevention Act Potential legislation similar to H.R. 8045, Critical Minerals Classification Improvement Act Potential legislation similar to H.R. 8998, Department of the Interior, Environment, and Related Agencies Appropriations Act, 2025 Potential legislation similar to S. 1863, Providing Reliable, Objective, Verifiable Emissions Intensity and Transparency (PROVE IT) Act Potential legislation similar to S. 2228, Building Chips in America Act of 2023 Potential legislation similar to S. 3170, Revising and Enhancing Project Authorizations Impacted by Review (REPAIR) Act Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4753, Energy Permitting Reform Act of 2024 Potential legislation similar to S. 4815, Simplify Timelines and Assure Regulatory Transparency (START) Act Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low-Income Household Water Assistance Program (LIHWAP) Potential legislation similar to H.J.Res. 91/S.J.Res. 55, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to "National Environmental Policy Act Implementing Regulations Revisions Potential legislation similar to S.Con.Res. 14, A concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031 Final Rule, Department of Energy; Energy Conservation Program: Energy Conservation Standards for Distribution Transformers (89 Fed. Reg. 29,834-30,043, April 22, 2024) Final Rule, EPA New Source Performance Standards for Greenhouse Gas Emissions from New, Modified, and Reconstructed Fossil Fuel-Fired Electric Generating Units; Emission Guidelines for Greenhouse Gas Emissions from Existing Fossil Fuel-Fired Electric Generating Units; and Repeal of the Affordable Clean Energy Rule (89 Fed. Reg. 39,798-40,064, May 9, 2024) Proposed Regulations, Section 45V Credit for Production of Clean Hydrogen, Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 Fed. Reg. 89,220-89,255, December 26, 2023) Request for Information, Office of Management and Budget, Deregulation, (89 Fed. Reg. 15,481-15,482, April 11, 2025) Proposed Rule, Repeal of Greenhouse Gas Emissions Standards for Fossil Fuel-Fired Electric Generating Units (90 Fed. Reg. 25,752-25,781, June 17, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Copper (90 Fed. Reg. 11,940-11,941, March 13, 2025) Notice of Request for Public Comments on Section 232 National Security Investigation of Imports of Processed Critical Minerals and Derivative Products (90 Fed. Reg. 17,372-17,373, April 25, 2025) Various issues relating to regulatory permit streamlining; social cost of carbon in cost-benefit analyses underlying federal regulations; Keystone XL environmental assessment; diversifying energy sources, including the Trans-Adriatic Pipeline, offshore oil drilling, and wind energy; funding for energy efficiency programs; establishing a durable program for managing used nuclear fuel; nuclear fuel storage at Yucca Mountain; funding for the Advanced Research Projects Agency-Energy (ARPA-E) program; Agency Unified Agenda of Regulatory and Deregulatory Actions more broadly; Agency deregulatory announcements and initiatives generally; Department of Interior leasing ban and royalty review; strategic petroleum reserve; State Department interim international energy engagement guidance; electric grid reliability, resiliency, increasing demand growth, and resource adequacy/energy security, including interdependencies of natural gas and electricity markets; critical minerals, generally: energy security, including implications for national security and natural gas and liquified natural gas exports; limitations on exports of energy commodities, including liquified natural gas; Bureau of Land Management Leasing program; offshore energy exploration, including Bureau of Ocean Energy Management proposed program for the 2023-2028 National Outer Continental Shelf Oil and Gas Leasing Program; nuclear energy, including high-assay low-enriched uranium (HALEU) fuel supplies; electric transmission siting and permitting; implementation of the Natural Gas Act (P.L. 75-688); development of solar energy; development of water power; implementation of the Advanced Nuclear Fuel Availability Program, as modified by the Nuclear Fuel Security Act of 2023 (P.L. No. 118-31); continuation of the percentage depletion tax deduction; preservation of the Clean Hydrogen Production Tax Credit regulations under section 45V (45V); cybersecurity regulations applicable to critical infrastructure and associated supply chains, including software bills of materials and cyber incident reporting relating to the Cyber Incident Reporting for Critical Infrastructure (CIRCIA) Act of 2022; development of and Initial Implementation Guidance from the Office of Management and Budget on the Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (April 18, 2022); implementation of hydrogen production tax credit under the Inflation Reduction Act (P.L. 117-169); implementation of the Inflation Reduction Act of 2022 (P.L. No. 117-19); confirmation of new commissioners nominated to serve on the Federal Energy Regulatory Commission; executive compensation at energy companies relative to corporate tax liabilities; electricity pricing at the state level and impact of infrastructure constraints on same; applicability of the Energy Policy and Conservation Act to distribution transformers; artificial intelligence, data centers, and interaction with electricity grid, rates, and markets; Inflation Reduction Act tax credits and their potential modification; potential Administration or agency actions affecting bulk power system supply chains