VALOR Act of 2025

S.3198, Foreign Pollution Fee Act, including provisions related to fee structures and environmental impacts from industrial operations. H.R. 6622 / S. 3422, Clean Competition Act, including provisions related to carbon emissions and the carbon border adjustment mechanism. H.R. 6665, Market Choice Act, including provisions related to carbon emissions and decarbonization incentive structures. S.1863, PROVE It Act, including provisions related to DOE conducting a study of carbon emissions of specific products. Issues related to potential changes to the listings on the Endangered Species Act. Potential House and Senate Legislation related to broader permitting reform efforts. U.S. Council on Environmental Qualitys Request for Information, Environmental Justice Scorecard, CEQ-2023-0005, (November 20, 2023), including provisions related to chemical industry responses. U.S. Environmental Protection Agency Final Rule, National Ambient Air Quality Standards for Particulate Matter, EPA-HQ-OAR-2015-0072, (March 6, 2024), including provisions related to feasibility and implementation. H.J.Res.161, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. S.J.Res. 100, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. Issues related to the EPAs Good Neighbor Rule including potential regulatory burden on industrial operations. U.S. Environmental Protection Agency, Regional Haze Plan, Air Plan Partial Approval and Partial Disapproval Wyoming, EPA-R08-OAR-2023-0489; Air Plan Partial Approval and Partial (August 1, 2024), including provisions related to feasibility and implementation. U.S. Environmental Protection Agency, National Ambient Air Quality Standard for Particulate Matter 2.5, including provisions related to feasibility and implementation. H.R. 7284, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. S. 3724, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. Issues related to State vs. Federal primacy in the execution of CAA Title V permits.

Client expense: $10,000 · Firm income: Not reported

Government targets: Council on Environmental Quality (CEQ), Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling Clean Competition Act of 2025 S. 1863, the PROVE IT Act S. 1325, the Foreign Pollution Fee Act HR 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act HR 4218, Clean Air and Economic Advancement Reform (CLEAR) Act HR 4214, Clean Air and Building Infrastructure Improvement Act HR 161, New Source Review Permitting Improvement Act HR 6409, Foreign Emissions and Nonattainment Clarification for Economic Stability (FENCES) HR 6387, Fire Improvement and Reforming Exceptional Events (FIRE) Act HR 6373, Air Permitting Improvements to Protect National Security Act HR 6398, Reducing and Eliminating Duplicative Environmental Regulations (RED Tape) Act

Client expense: $810,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

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

S.3198, Foreign Pollution Fee Act, including provisions related to fee structures and environmental impacts from industrial operations. H.R. 6622 / S. 3422, Clean Competition Act, including provisions related to carbon emissions and the carbon border adjustment mechanism. H.R. 6665, Market Choice Act, including provisions related to carbon emissions and decarbonization incentive structures. S.1863, PROVE It Act, including provisions related to DOE conducting a study of carbon emissions of specific products. Issues related to potential changes to the listings on the Endangered Species Act. Potential House and Senate Legislation related to broader permitting reform efforts. U.S. Council on Environmental Qualitys Request for Information, Environmental Justice Scorecard, CEQ-2023-0005, (November 20, 2023), including provisions related to chemical industry responses. U.S. Environmental Protection Agency Final Rule, National Ambient Air Quality Standards for Particulate Matter, EPA-HQ-OAR-2015-0072, (March 6, 2024), including provisions related to feasibility and implementation. H.J.Res.161, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. S.J.Res. 100, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. Issues related to the EPAs Good Neighbor Rule including potential regulatory burden on industrial operations. U.S. Environmental Protection Agency, Regional Haze Plan, Air Plan Partial Approval and Partial Disapproval Wyoming, EPA-R08-OAR-2023-0489; Air Plan Partial Approval and Partial (August 1, 2024), including provisions related to feasibility and implementation. U.S. Environmental Protection Agency, National Ambient Air Quality Standard for Particulate Matter 2.5, including provisions related to feasibility and implementation. H.R. 7284, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. S. 3724, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. Issues related to State vs. Federal primacy in the execution of CAA Title V permits.

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

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling Clean Energy Standard legislation S. 1863, the PROVE IT Act S. 1325, the Foreign Pollution Fee Act HR 4776, Standardizing Permitting and Expediting Economic Development (SPEED) Act

Client expense: $580,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.3198, Foreign Pollution Fee Act, including provisions related to fee structures and environmental impacts from industrial operations. H.R. 6622 / S. 3422, Clean Competition Act, including provisions related to carbon emissions and the carbon border adjustment mechanism. H.R. 6665, Market Choice Act, including provisions related to carbon emissions and decarbonization incentive structures. S.1863, PROVE It Act, including provisions related to DOE conducting a study of carbon emissions of specific products. Issues related to potential changes to the listings on the Endangered Species Act. Potential House and Senate Legislation related to broader permitting reform efforts. U.S. Council on Environmental Qualitys Request for Information, Environmental Justice Scorecard, CEQ-2023-0005, (November 20, 2023), including provisions related to chemical industry responses. U.S. Environmental Protection Agency Final Rule, National Ambient Air Quality Standards for Particulate Matter, EPA-HQ-OAR-2015-0072, (March 6, 2024), including provisions related to feasibility and implementation. H.J.Res.161, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. S.J.Res. 100, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. Issues related to the EPAs Good Neighbor Rule including potential regulatory burden on industrial operations. U.S. Environmental Protection Agency, Regional Haze Plan, Air Plan Partial Approval and Partial Disapproval Wyoming, EPA-R08-OAR-2023-0489; Air Plan Partial Approval and Partial (August 1, 2024), including provisions related to feasibility and implementation. U.S. Environmental Protection Agency, National Ambient Air Quality Standard for Particulate Matter 2.5, including provisions related to feasibility and implementation. H.R. 7284, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. S. 3724, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. Issues related to State vs. Federal primacy in the execution of CAA Title V permits.

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

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling Clean Energy Standard legislation S. 1863, the PROVE IT Act S. 1325, the Foreign Pollution Fee Act

Client expense: $820,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1863/H.R.7198 - PROVE IT Act, S.3198 - Foreign Pollution Fee Act, and S.4355/H.R.6622 - Clean Competition Act. BASF supports carbon leakage solutions that create a level global playing field for low product carbon footprint products and are consistent with WTO obligations and other applicable agreements. Plastics (S.351 - STEWARD Act). BASF supports policies to promote recycling and composting, and to improve and enhance recovery and recycling infrastructure, rather than ban or tax certain products. Open Competition (no bills). BASF supports public policies that ensure open, competitive bidding procedures be used for selection of materials for federally-funded infrastructure projects. Microplastics (no bills). BASF supports public policies that seek to reduce plastic pollution in the environment, including pollution from nanoplastics and microplastics. Global Plastics Treaty (no bills). BASF supports the development of a global plastics treaty to eliminate plastic pollution and the use of all innovative recycling technologies to achieve this goal. Advanced Recycling and Mass Balance (no bills). BASF supports public policies that seek to formally recognize advanced recycling technologies and mass balance accounting as critical to growing the circular economy, eliminating plastic pollution, and protecting the environment. No IRIS Act (S.623); Implementation of 2016 reforms to Toxic Substances Control Act [P.L.94-469]. BASF supports regulatory processes that are science-based, transparent, and stable, as well as increased EPA funding and staffing and increased regulatory efficiency so that safe, sustainable chemistries can reach the market in a timely manner. EnergyStar Appropriations (Fiscal Year 2026 Energy and Water Development and Related Agencies Bill - no bill number). BASF supports the continued existence of the EnergyStar program jointly administered by DOE and EPA. Redrafting/Revising Renewable Chemical Act (previously H.R.6532/S.4931 in 118th session). BASF supports approaches that improve accessibility, usability, and recognition of mass balance accounting methodology.

S.3198, Foreign Pollution Fee Act, including provisions related to fee structures and environmental impacts from industrial operations. H.R. 6622 / S. 3422, Clean Competition Act, including provisions related to carbon emissions and the carbon border adjustment mechanism. H.R. 6665, Market Choice Act, including provisions related to carbon emissions and decarbonization incentive structures. S.1863, PROVE It Act, including provisions related to DOE conducting a study of carbon emissions of specific products. Issues related to potential changes to the listings on the Endangered Species Act. Potential House and Senate Legislation related to broader permitting reform efforts. U.S. Council on Environmental Qualitys Request for Information, Environmental Justice Scorecard, CEQ-2023-0005, (November 20, 2023), including provisions related to chemical industry responses. U.S. Environmental Protection Agency Final Rule, National Ambient Air Quality Standards for Particulate Matter, EPA-HQ-OAR-2015-0072, (March 6, 2024), including provisions related to feasibility and implementation. H.J.Res.161, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. S.J.Res. 100, disapproving New Source Performance Standards for the Synthetic Organic Chemical Manufacturing Industry and National Emission Standards for Hazardous Air Pollutants for the Synthetic Organic Chemical Manufacturing Industry and Group I & II Polymers and Resins Industry, issues related to EPAs New Source Performance Standards. Issues related to the EPAs Good Neighbor Rule including potential regulatory burden on industrial operations. U.S. Environmental Protection Agency, Regional Haze Plan, Air Plan Partial Approval and Partial Disapproval Wyoming, EPA-R08-OAR-2023-0489; Air Plan Partial Approval and Partial (August 1, 2024), including provisions related to feasibility and implementation. U.S. Environmental Protection Agency, National Ambient Air Quality Standard for Particulate Matter 2.5, including provisions related to feasibility and implementation. H.R. 7284, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. S. 3724, No IRIS Act 2024, including provisions related to the enactment and usage of IRIS at EPA. Issues related to State vs. Federal primacy in the execution of CAA Title V permits.

H.R. 755/S. 714, Critical Mineral Consistency 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 Indo-Pacific Strategic Energy Initiative Act Draft legislation requiring manual operations capabilities for critical infrastructure Draft legislation titled Promoting Efficient and Engaged Reviews Act of 2023 Draft legislation titled Modernizing NEPA Through Permitting Reform Act Potential legislation similar to H.R. 1, Lower Energy Costs Act Potential legislation similar to H.R. 209, Permitting for Mining Needs Act of 2023 Potential legislation similar to H.R. 1068, Securing Americas Critical Minerals Supply 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. 1115, Promoting Interagency Coordination for Review of Natural Gas Pipelines 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. 1160, Critical Electric Infrastructure Cybersecurity Incident Reporting Act Potential legislation similar to H.R. 1335, Transparency, Accountability, Permitting, and Production of (TAPP) American Resources Act Potential legislation similar to H.R. 1435, Preserving Choice in Vehicle Purchases 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. 2670, National Defense Authorization Act for Fiscal Year 2024 Potential legislation similar to H.R. 2925, Mining Regulatory Clarity Act of 2023 Potential legislation similar to H.R. 3081/S. 678, No Oil Producing and Exporting Cartels (NOPEC) Act of 2023 Potential legislation similar to H.R. 3684, Infrastructure Investment and Jobs Act Potential legislation similar to H.R. 3746, Fiscal Responsibility Act of 2023 Potential legislation similar to H.R. 4468, Choice in Automobile Retail Sales (CARS) Act Potential legislation similar to H.R. 4720/S. 2475, Energy Sector Innovation Credit Act of 2021 Potential legislation similar to H.R. 5376, Build Back Better 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. 6544, Atomic Energy Advancement Act Potential legislation similar to H.R. 7023, Creating Confidence in Clean Water Permitting Act Potential legislation similar to H.R. 7176, Unlocking our Domestic LNG Potential Act of 2024 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. 8070, Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025 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. 2226, National Defense Authorization Act for Fiscal Year 2024 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. 4064, International Nuclear Energy Act Potential legislation similar to S. 4066, Fueling Our Nuclear Future Act of 2022 Potential legislation similar to S. 4217, Transportation Fuel Market Transparency Act Potential legislation similar to S. 4638, National Defense Authorization Act for Fiscal Year 2025 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 legislation similar to H.J.Res. 117/S.J.Res. 65, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to Reconsideration of the National Ambient Air Quality Standards for Particulate Matter Potential legislation similar to H.J.Res. 163/S.J.Res. 92, Providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Environmental Protection Agency relating to 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 Potential legislation similar to H.J.Res.168/S.J.Res. 99, 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 Phase 2" 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 Potential appropriations bills addressing Low Income Home Energy Assistance Program (LIHEAP) and Low Income Household Water Assistance Program (LIHWAP) Nomination of Chris Wright to be Secretary of the Department of Energy Notice of Proposed Rulemaking, Federal Energy Regulatory Commission; Applications for Permits to Site Interstate Electric Transmission Facilities (88 Fed. Reg. 2,770-2,794, January 17, 2023) 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) 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; Department of Interior leasing ban and royalty review; Federal Energy Regulatory Commission (FERC) Updated Policy Statement on Certification of New Interstate Natural Gas Facilities; Federal Energy Regulatory Commission (FERC) Interim Policy Statement on the Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews; Federal Energy Regulatory Commission (FERC) Reliability Technical Conference in Docket No. AD23-9-000; 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; proposed 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; G7 Supply Chain Cybersecurity Principles from Department of Energy and White House Council on Supply Chain Resilience; 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); Department of Energy National Interest Electric Transmission Corridor designation process; 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

Carbon Neutrality of Biomass Air Permitting Green House Gas Regulation/Climate Policy Paper Recycling Clean Energy Standard legislation S. 1863, the PROVE IT Act S. 1325, the Foreign Pollution Fee Act

Client expense: $570,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1863/H.R.7198 - PROVE IT Act, S.3198 - Foreign Pollution Fee Act and S.4355/H.R. 6622 - Clean Competition Act. BASF supports carbon leakage solutions that create a level global playing field for low product carbon footprint products and are consistent with WTO obligations and other applicable agreements. Plastics (S.351 - STEWARD Act). BASF supports policies to promote recycling and composting, and to improve and enhance recover and recycling infrastructure, rather than ban or tax certain products. Open Competition (no bills). BASF supports public policies that ensure open, competitive bidding procedures be used for selection of materials for federally-funded infrastructure projects. Microplastics (no bills). BASF supports public policies that seek to reduce plastic pollution in the environment, including pollution from nanoplastics and microplastics. Global Plastics Treaty (no bills). BASF supports the development of a global plastics treaty to eliminate plastic pollution and the use of all innovative recycling technologies to achieve this goal. Implementation of 2016 reforms to Toxic Substances Control Act [P.L.94-469]. BASF supports regulatory processes that are science-based, transparent, and stable, as well as increased EPA funding and staffing and increased regulatory efficiency so that safe, sustainable chemistries can reach the market in a timely manner.

Client expense: $1,050,000 · Firm income: Not reported