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Chemical Industry Update - June 2019

June 3, 2019

by Troy M. Keller, Kent J. Schmidt, Dave Townsend, Anthony P. Badaracco, and T. Augustine Lo

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"This is the last worthless evening that you'll have to spend"

This Don Henley song from the ‘90s may not have been a classic (it's post-Eagles after all), but it conveyed a certain upbeat melancholy that was memorable.  It acknowledged that the world can be rough, and in the same breath promised the worst was going to be behind you.  As a business metaphor, you might say this line captures the feeling management has when a major challenge like burdensome litigation is finally resolved.  Now we can get back to business!  

Unfortunately, in the chemical industry that sentiment is becoming more and more elusive.  For many, litigation and other forms of legal exposure have become persistent companions.  

We have reported in prior issues on the proliferation of litigation associated with a variety of chemical products.  Tort liability (relating to talc litigation) even led to a major bankruptcy announcement earlier this year. As minefields increase, it becomes important to identify potential sources of liability as early as possible and be prepared with a strategy before the worst arrives.

In this issue, we offer some insights into areas of potential exposure that might not have been on your radar.  A good example is the recent update to California's Proposition 65, which creates a pathway for direct liability to move upstream to raw materials suppliers.  Immigration law trends have also added to compliance risks, as has the evolution of antitrust enforcement activity around the world.  We touch on these and others.  And, because M&A transactions can expose unsuspecting buyers to new markets with different risk profiles, we offer some thoughts and strategies for due diligence in transactions in which new product lines are being added.  Take a look, and let us know if you have questions.

Prop 65 Liability Update

Over 30 years have passed since this California voter-initiative was passed, and the law remains as potent as ever today.  In 1987, the Governor’s List of chemicals requiring a Prop 65 warning was 30—today, it is over 900. Prop 65 has created a thriving cottage industry of litigation boutiques, enforcing the law through lucrative private actions, spurred by the threat of draconian penalties ($2,500 per exposure) and public interest attorney fees.  

Liability for Upstream Suppliers.  Because most Prop 65 litigation is brought against the retailers or direct manufacturers, the law’s impact on chemical companies has historically been more indirect, such as from product deselection by retailers and manufacturers who avoid listed products.  Amendments enacted in 2018 have the purpose and effect of shifting the responsibility upstream, recognizing retailers’ rights to limit their own liability by seeking reps and warranties and contractual indemnity to upstream manufacturers and raw material suppliers.  A great deal of attention is being given to contractual provisions governing the relationships between raw material suppliers, manufacturers of component parts and other parties in the stream of commence. We have been advising several clients positioned at various points in the distribution chain to utilize appropriate contract terms and best practices in addressing Prop 65 liabilities.

Propagation of Similar Statutes and Industry Response.  Legislation similar to Prop 65 has been introduced in other jurisdictions such as Illinois, Maine, Oregon and Washington, as lawmakers seek to regulate various types of exposures, particularly in children’s products.  Supported by the American Chemistry Council, the Accurate Labels Act (S. 3019 / H.R. 6022) is a bill introduced in Congress in 2018 that would place limits and add requirements to state labeling regimes such as Prop 65.  While not expressly preempting state labeling requirements, the law would add standards and limit the reach of these state standards, requiring science-based criteria and exempting liabilities for products with trace amounts of certain substances.  

For more information, contact Kent Schmidt.

Immigration Audits Create Risk for Employers

Many employers have been subjected to audit notices from Immigration and Customs Enforcement (ICE).  According to ICE’s own website, it has increased its I-9 audits by more than 300 percent since President Trump signed the “Buy American and Hire American” Executive Order two years ago, on April 18, 2017.  We recommend that employers secure legal counsel if they receive such a notice.  ICE has broad subpoena powers and the ability to impose civil and criminal penalties on employers who fail to comply with their obligations to complete and maintain forms I-9 as required by the Immigration Reform and Control Act (IRCA).  

ICE has authority over companies that engage independent contractors too.  If ICE believes the company is classifying workers as independent contractors (or using a third-party staffing company) to avoid the requirement to complete a form I-9, and is knowingly engaging foreign nationals without work authorization, it can impose penalties on that company.  

In addition to the increased ICE audits, in March of 2019, the Social Security Administration (SSA) resumed its practice of sending “no match” letters to employers when the names on W-2 (or other IRS forms) do not match the social security numbers.  As it notes on its website, it is encouraging employers to correct such errors and to file the Form W-2c with any corrections necessary.  

It is important to keep in mind that a no-match letter does not automatically mean that an employee is not authorized to work in the U.S. or that the employer will also receive a notice of audit from ICE.  The SSA sets different verification requirements and it is important to realize that deviating from the obligations to correct W-2 mistakes with the SSA may create discrimination liability under other laws protecting employees (including workers not authorized to work in the U.S.).  

Immigrant and Employee Rights Section (IER) investigates discriminatory treatment during the Form I-9 and E-Verify processes.  Employers may not discriminate, based on citizenship status or national origin, nor because of an accent.  IER would also have jurisdiction to investigate discriminatory treatment if an employer is attempting to resolve an SSA no match notice.

For more information, contact Rebecca J. Bernhard.

Antitrust Trends for Manufacturers

While antitrust enforcement and policy reform targeting the tech industry have been much in the headlines of late, competition laws around the world create compliance risk for companies of all shapes and sizes.  The chemical and materials industries are no exception.  We have noticed several trends around the world that are particularly relevant for manufacturing companies.  

  • Cartel Enforcement.  Several countries have indicated they are strengthening their cartel enforcement regimes.  Malaysia’s competition commission resolved its first bid-rigging case, and Australia’s commission has opened new cartel enforcement actions and indicated that it intends to continue becoming more active.  Thailand, a country that adopted competition law regime in 1999 but to date has not lodged a cartel action, recently restructured its regulatory body in anticipation of becoming active in terms of enforcement.  (See more in this article from the East Asia Forum.)  India and China continue to grow their enforcement agencies and to be more muscular in their approach.
  • Vertical Mergers.  In terms of merger control, the U.S. Department of Justice recently litigated a vertical merger case for the first time in 40 years (in this case, in the media industry).  Though the DOJ lost, leaders from both federal enforcement agencies have indicated that they are investigating other mergers with a focus on vertical theories of harm.  The European Union has long relied on vertical theories in its review processes, as has China.  This has always been of particular relevance to the chemical industry, where business lines are frequently back-integrated.  With many companies moving downstream into materials and formulations, vertical merger enforcement becomes even more relevant.
  • ACPERA Renewal.  The Antitrust Criminal Penalty Enhancement and Reform Act (ACPERA) in the U.S. allows a company that self-reports illegal cartel activity to the Department of Justice to be liable for only single, rather than trebled, damages in any follow-on civil suits. That law is up for renewal in June 2019. Following recent hearings, everyone seems to agree it will (and should) be renewed because it is a powerful incentive for companies to assist the government, which increases the likelihood that cartels are detected and prosecuted efficiently. 

For more information, contact Anthony Badaracco.  

Mexico Tariffs and Risks for USMCA

On Thursday, May 30, 2019, the White House threatened to impose a series of escalating tariffs on U.S. imports from Mexico, starting at five percent on June 10, and scheduled to increase to 25 percent by October 1, 2019.  Citing the influx of migrants crossing the U.S.-Mexican border, the White House indicated that the tariffs would take effect unless the Mexican government significantly abates the problem in the “sole discretion and judgment” of the Trump administration.

As support for this threatened measure, the White House cited presidential authority under the International Emergency Economic Powers Act (IEEPA).  In the past, presidents have invoked IEEPA to impose economic sanctions on hostile foreign countries and persons who engage in actions that are inimical to U.S. interests (e.g., Iran, Syria, North Korea, Russia, and Venezuela). 

This appears to be the first time that a U.S. administration has invoked IEEPA against a major trade partner.  It also appears to be the first time that a president has invoked IEEPA to levy an import tariff, instead of prohibiting commerce with a hostile foreign party.  

At this time, it is uncertain how the threatened tariffs will impact the approval of the recently signed U.S.-Mexico-Canada Agreement (USMCA), which is supposed to replace the North American Free Trade Agreement (NAFTA).  Canada and Mexico recently reached agreement with the United States to lift the U.S. Section 232 tariffs on steel and aluminum articles to facilitate USMCA approval in the three countries.  If implemented, these new tariffs could create a new obstacle for that effort.  

We also see a likelihood of legal challenges to these new tariffs.  As NAFTA remains in force, Mexico may invoke NAFTA’s dispute resolution procedures to challenge the new tariffs.  Also, private parties can mount a challenge in U.S. courts, seeking to prevent the application of the tariffs on goods imported into the United States.

For more information, contact David Townsend or Augustine Lo.

In Case You Missed It

California Bill Would Exclude Employee Information from California’s Consumer Privacy Law.  Our eUpdate summarizes the bill that passed the California Assembly and is now moving to the state’s Senate.

OFAC Provides Sanctions Guidance.  Our eUpdate discusses new guidance from OFAC with respect to implementing effective sanctions compliance programs.

China Opens Tariff Exclusion Process.  Our eUpdate discusses the most recent round of 301 tariffs, China’s retaliatory steps and an exclusion process being run in China. 

Notes from All Over

Cefic’s New President Comments on Circular Economy.  Daniele Ferrari, CEO of Versalis and President of Cefic, comments on the chemical industry’s role in solving sustainability challenges and promoting a circular economy.

Washington Chemical Law.  In May, Washington State passed the Pollution Prevention for Our Future Act, perhaps the strongest state law regulating toxic chemicals in products.  It prioritizes a number of chemical classes for determination and action.

More Criminal Charges Levied in Texas Against Chemical Companies.  As yet another example of Harris County’s aggressive approach toward chemical companies, misdemeanor criminal charges were brought against Intercontinental Terminals Company for pollution arising from a fire in March that sent smoke over the Houston area.

Basel Convention Amendment Reduces Options for Plastics Recycling.  187 governments agreed to changes to a global waste treaty that limits movement of mixed-plastic bales of waste across borders. 

EU Parliament Weighing in on Chemicals Policy.  For technical, chemreg actions, the Parliament has historically been viewed as providing a rubber stamp to the outcomes of the European Commission’s extensive and technical processes.  Recent actions show the Parliament being more aggressive. 

FMC Spinoff Hit with Securities Litigation.  On May 23, Livent Corp., a producer of lithium compounds, was sued in a shareholder lawsuit alleging that in its IPO it failed to disclose it had lost a key supplier and other facts  (Note: this article is behind a paywall).

WOTUS Decision.  Last week, the Waters of the United States rule was struck down by the U.S. Court for the Southern District of Texas for violating aspects of the Administrative Procedures Act.  WOTUS was adopted in 2015 under the Obama Administration has been controversial from the start with its significant expansion of federal jurisdiction over small and isolated bodies of water.  It was challenged in a number of courts and then was suspended by the EPA in early 2018.  Earlier this year, the Trump Administration issued proposed rulemaking to effectively replace the rule.  

MERGERS & ACQUISITIONS

Due Diligence Trends & Strategies

Nearly every M&A transaction begins with a look at the possibilities: the strategic fit; the synergies; the drivers for the deal.  Naturally enough, the next step will turn to an evaluation of risk.  Traditionally, legal exposure from toxic tort and other forms of product liability has rated high on the list of issues to identify and protect against—up there with environmental liabilities and compliance exposures.  Recently, however, eye-popping damage awards have raised the stakes, suggesting that acquirers may consider additional due diligence steps, particularly when acquiring new product lines in businesses with which they are less familiar.  

In the past, during the due diligence phase one would expect to negotiate liability protections with respect to existing and threatened litigation.  If a target company had asbestos exposure for example, that docket and the potential for additional cases would be assessed and indemnities might be negotiated or a reps & warranties insurance policy might be entered into to cover that risk.  But trying to protect against legal liability that may emerge in the future has been viewed as a speculative exercise.  It has been in the category of “risk factors” that a buyer simply needed to swallow or factor into the price it was willing to offer. 

The Bayer – Monsanto merger may have changed things.  Two weeks ago, Fortune reported that Bayer’s stock price has fallen over 44 percent since the merger closed and tied the fall to shareholder worries about exposure from glyphosate litigation.  Glyphosate had been a controversial product for some time, but this had not translated into direct legal liability prior to the merger.  Bayer clearly felt that the opportunities outweighed the risks.  

Deals will always be evaluated in hindsight, and risk assessment is never perfect.  There is a point where people are indeed just speculating.  But buyers can and should avail themselves of every opportunity to understand regulatory, industry and social trends that may impact the value of their acquisition in the future.  This could mean going beyond some of the standard techniques.

One aspect of this type of expanded due diligence involves hiring the right advisors.  Private equity buyers have long understood the importance of hiring industry consultants when evaluating a business.  Strategic buyers may have less of a need, given they bring their own internal experts, but when getting into a new line of business, they may need to think more like private equity.  

Regulatory trends should also be reviewed.  Products that have been vetted through a fulsome regulatory process (such as Europe’s REACH process) may be less likely to face challenges in other jurisdictions.  On the flipside, if a target’s products are listed or proposed to be listed as priorities for action in states like California or Washington, this obviously should raise red flags.

Getting access to the right people during the due diligence process is key.  A group that is sometimes overlooked is product managers.  These are the line managers who are in the weeds of the day-to-day discussions with customers and other industry players.  They spend their time worrying what might change across the landscape in which they sell.  Particularly, if an acquirer is looking to bring in new product lines it is not familiar with, discussions with the relevant product managers can be revealing. 

Finally, some law firms (like ours) are becoming more industry focused because of the simple fact that it lets us bring regulatory and industry knowledge that is fit-for-purpose.  In the ordinary course, legal advisors tend to be at the center of the due diligence process anyway since identified risks need to be factored into the liability provisions of the contract.  Having a team of lawyers who understand your industry well allows them to ask the right questions and filter the information more effectively.

For more information, contact Troy Keller.  

SEC Rulemaking on Proxy Advisors and Shareholder Proposals

Since its Proxy Roundtable last fall, the SEC has continued to send signals that it is serious about looking to make changes in the way that proxy advisors are regulated and shareholder proposals are made.  Given the number of shareholder proposals that target the chemical industry and several of its key downstream markets, such as food and agriculture, regulations that push for more fairness in these areas are likely to be welcomed.  Last week, the SEC posted formal notice of its intention to propose rules in these and other areas this year.  

For more information, contact Troy Keller.  

To learn more about Dorsey’s chemical industry practice, contact Troy Keller.

Firm Highlights

Insights

SEC Proposes Expansion of Investment Adviser Performance-Based Compensation Rule

On September 30, 2026, the Securities and Exchange Commission (the “SEC”) proposed amendments to Rule 205-3 under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), which provides an exemption from the general prohibition under Section 205(a)(1) of the Advisers Act on registered investment advisers receiving performance-based compensation (the “Proposal”) so long as performance-based compensation is limited to “qualified clients”.1 Most notably for private fund sponsors, the Proposal would expand the definition of “qualified client” to include any investors that satisfy the “accredited investor” definition under Regulation D. The Proposal may also have implications for private fund managers that rely on exemptions from investment adviser registration under state law because certain state-level investment adviser registration exemptions incorporate or otherwise reference the federal qualified client definition. Expansion of the Qualified Client Definition Under the current Rule 205-3, an investor generally may qualify as a qualified client if, among other alternatives, the investor has at least $1.4 million under management with the adviser or has a net worth exceeding $2.7 million. These thresholds are higher than the financial thresholds applicable to many accredited investors under Regulation D. As a result, an investor may currently qualify as an accredited investor for purposes of investing in a private offering without qualifying as a qualified client for purposes of paying performance-based compensation. The Proposal would expand the qualified client definition to include any natural person or legal entity investor that satisfies the accredited investor definition under Regulation D. The Proposal would also remove the assets under management and net worth thresholds under the current Rule 205-3 qualified client test. For private funds relying on Section 3(c)(1) of the Investment Company Act of 1940, this change could reduce the need to apply a separate qualified client standard to investors that already qualify as accredited investors. Dorsey Observations and Next Steps If adopted as proposed, the expanded qualified client definition could be particularly significant for private fund managers. Most private fund offerings are already limited to accredited investors under Regulation D. However, the Proposal could expand the pool of prospective investors available to emerging private fund managers while reducing the regulatory burden associated with complying with Rule 205-3. The Proposal could also benefit advisers operating below the SEC registration threshold that rely on a state private fund adviser exemption. A number of states have adopted exemptions modeled on the North American Securities Administrators Association (“NASAA”) private fund adviser exemption, which may condition relief for advisers to certain funds relying on Section 3(c)(1) on each beneficial owner satisfying the federal qualified client definition. However, state requirements vary, and any effect of the Proposal would depend on the text of the applicable state exemption and how it incorporates Rule 205-3. Many emerging private fund managers may have a larger network of accredited investor relationships than qualified client relationships during the early stages of their investment advisory business. Currently, under Rule 205-3, private fund managers may receive performance-based compensation from investors who do not satisfy the qualified client definition if those investors were admitted to their private funds prior to registration with the SEC. Following registration with the SEC, however, managers may continue to permit investors that are not qualified clients to invest in future private funds but may not receive performance-based compensation from those investors with respect to such investments. In addition, because the net worth and assets under management thresholds for qualified client status are adjusted for inflation every five years, the pool of qualified client investors may diminish over time as previously eligible investors no longer satisfy the applicable thresholds. The Proposal could provide the dual benefit of greater flexibility for private fund managers to establish and maintain relationships with accredited investors as their businesses scale and they become registered with the SEC, and greater flexibility for certain accredited investors to participate in investment strategies that historically have been restricted to much larger institutional investors. Unless and until the Proposal is adopted, investment advisers should continue to comply with the existing qualified client requirements. If the Proposal is adopted, private fund sponsors should consider whether corresponding changes are appropriate for their subscription documents, investor questionnaires, and other offering materials. Advisers that are state-registered or rely on a state-level exemption should also consult the laws and regulations of each relevant jurisdiction before changing investor eligibility standards or performance-based compensation practices, because adoption of the federal amendments may not automatically modify state requirements. Comments on the Proposal will be due 60 days after publication in the Federal Register. 1 Investment Adviser Performance-Based Compensation Modernization, Investment Advisers Act Release No. IA-7022 (Sept. 30, 2026), available at https://www.sec.gov/rules-regulations/2026/09/s7-2026-28#33-11443proposed.

Insights

EPA Limits Title V Re-Litigation of NSR Permits

Overview On September 25, 2026, the U.S. Environmental Protection Agency (“EPA”) published a final rule that significantly limits the ability of third parties to use the Clean Air Act (“CAA”) Title V permitting process to revisit New Source Review (“NSR”) permitting decisions years after those decisions were made. The rule establishes that NSR permitting determinations generally must be challenged during the original permitting proceeding, thereby providing regulated sources with greater permitting certainty and finality for major capital projects. Published in the Federal Register titled Clarifying the Scope of “Applicable Requirements” Under State Operating Permit Programs and the Federal Operating Permit Program (Docket ID No. EPA-HQ-OAR-2023-0401), the rule amends 40 C.F.R. Parts 70 and 71 to codify EPA’s interpretation regarding when requirements established under other CAA programs may be reviewed, modified, or implemented through the Title V operating permit program. The rule becomes effective 30 days after publication. The rule addresses two principal issues: (1) the relationship between NSR preconstruction permitting and Title V operating permits, and (2) the treatment of the General Duty Clause under CAA section 112(r)(1). Most significantly, the rule provides greater certainty for sources navigating the NSR permitting process. EPA’s amendments are intended to ensure that NSR permitting decisions made through an approved public process are generally not revisited later through Title V permit proceedings. The rule responds to a circuit split between the U.S. Courts of Appeals for the Fifth and Tenth Circuits. In Environmental Integrity Project v. EPA, 969 F.3d 529 (5th Cir. 2020), the Fifth Circuit upheld EPA’s interpretation, concluding that it was consistent with the text, structure, and purpose of Title V. In contrast, the Tenth Circuit reached the opposite conclusion in Sierra Club v. EPA, 964 F.3d 882 (10th Cir. 2020), finding that the then-existing regulatory definition of “applicable requirement” did not support EPA’s position. By amending the regulatory language on which the Tenth Circuit relied and codifying the interpretation approved by the Fifth Circuit, EPA has established a nationwide framework governing the interaction between NSR and Title V. NSR and Title V: EPA Establishes a Uniform Nationwide Framework At the core of the rule is EPA’s effort to define the respective roles of NSR and Title V. The rule codifies the approach EPA has applied since 2017: once a source obtains an NSR permit under an EPA-approved permitting program, and that permit was issued following public notice with an opportunity for comment and judicial review, the permit establishes the NSR-related “applicable requirements” of the State Implementation Plan (“SIP”) or Federal Implementation Plan (“FIP”) for Title V purposes. Under this framework, Title V is not a vehicle for re-examining underlying NSR permitting decisions. EPA does not intend to use the Title V process to revisit applicability determinations, emissions calculations, control technology determinations, permit conditions, or other issues resolved through the NSR permitting process. This principle applies regardless of the stage of the Title V proceeding; whether the NSR permit was issued pursuant to a SIP or FIP; the type of NSR issue involved; or whether the NSR permit is incorporated into Title V sequentially or concurrently. Limited Exceptions EPA recognizes several circumstances in which NSR issues may still be reviewed through the Title V program: No NSR permit was issued at all; The permit was issued without public notice and an opportunity for comment and judicial review; or The issue involves substantive overlap between Title V and NSR requirements, such as the adequacy of monitoring provisions. As a result, the rule does not insulate unpermitted projects or foreclose review of matters that independently arise under Title V. Key Regulatory Amendments The rule revises the definition of “applicable requirement” in 40 C.F.R. §§ 70.2 and 71.2. Paragraph (1): Where an NSR permit is issued with public notice and an opportunity for comment and judicial review, the permit establishes and defines the applicable SIP or FIP requirements for Title V purposes. Paragraph (2): All NSR permit terms, including terms contained in minor NSR permits, constitute applicable requirements that must be incorporated into Title V permits. Paragraph (4): CAA section 112(r)(1) (the General Duty Clause) is expressly excluded from the definition of “applicable requirement,” while section 112(r)(7) Risk Management Program requirements remain included. EPA also amended 40 C.F.R. §§ 70.8 and 70.12 to clarify that alleged defects in requirements established outside the Title V process generally do not provide a basis for EPA objection to a Title V permit or for a Title V citizen petition. General Duty Clause Exclusion The rule also codifies EPA’s longstanding position that the General Duty Clause in CAA section 112(r)(1) is not an “applicable requirement” for Title V purposes. EPA points to several considerations supporting that conclusion, including the distinction between the General Duty Clause and Title V permit terms, the provision’s origins in the Occupational Safety and Health Act’s general duty clause, and the different enforcement structures applicable to the General Duty Clause and Title V permit requirements. Importantly, excluding section 112(r)(1) from the definition of “applicable requirement” does not eliminate EPA’s authority to enforce the General Duty Clause independently of the Title V program. The final rule instead clarifies that the General Duty Clause need not—and should not—be incorporated into Title V permits as an applicable requirement. Practical Implications for Regulated Sources Greater Finality for NSR Permits  For projects requiring PSD, nonattainment NSR, or minor NSR permits, the permitting process becomes the primary forum for resolving disputes regarding applicability determinations, emissions calculations, control technology requirements, offsets, and permit conditions. Once an NSR permit is issued through a qualifying public process, regulated sources should face substantially reduced risk that those same issues will be challenged years later through Title V permit proceedings. Reduced Risk of Collateral Permit Challenges Stakeholders have sometimes sought to use Title V permit issuance, renewal, revision, or citizen-petition proceedings to challenge underlying NSR determinations. The final rule makes clear that Title V is not the appropriate vehicle for challenging whether an applicable requirement was correctly established in the first instance. This should reduce the risk of permit delays and uncertainty associated with collateral challenges to previously issued NSR permits. The rule does not, however, eliminate all Title V challenges relating to an NSR permit. Challenges concerning the Title V permit itself—including whether it appropriately incorporates applicable requirements or contains adequate compliance provisions—remain possible. Increased Importance of the Initial NSR Proceeding Because Title V generally will not provide a second opportunity to challenge the substantive validity of an NSR determination, the administrative record developed during the NSR process becomes increasingly important. Permit applicants should ensure that applicability analyses, emissions calculations, control technology evaluations, modeling demonstrations, and supporting technical documentation are thoroughly developed during the original permitting proceeding. For significant projects, applicants may therefore have an additional incentive to identify and resolve potential permitting issues before the NSR permit is issued rather than assuming that unresolved issues can be addressed during a subsequent Title V proceeding. Potential Incentive for Broader Public Participation EPA also notes that permitting authorities may choose to provide public notice and an opportunity for comment for a broader range of NSR permits because permits issued through a qualifying public process receive the benefit of the finality framework established by the rule. Some permitting authorities may conclude that greater public participation at the NSR stage is preferable to uncertainty during subsequent Title V proceedings. Conclusion The final rule is principally a permitting-certainty measure. For sources that obtain NSR permits through a public process, EPA has substantially limited the ability of third parties to revisit underlying NSR determinations through the Title V program. As a result, regulated entities should benefit from greater finality regarding key permitting decisions, reduced risk of collateral permit challenges, and increased certainty when planning and implementing capital projects.

Insights

Energy Law: Month in Review - September 2026

Welcome to Dorsey’s Energy Law: Month in Review. We provide this update to our clients to identify significant developments in the previous month. Please reach out to any of the authors, listed above, to discuss these issues. Regulatory Developments Massachusetts Ratchets Up State and Local Regulation of AI Data Centers In early September, Governor Maura Healey of Massachusetts signed an executive order requiring that artificial intelligence data centers secure the approval of local communities as a precondition to proceeding with a given project. According to the terms of the order, data center developers will need to secure a “community benefits agreement” as a precondition to receiving permits from numerous state agencies, including the Department of Environmental Protection, the Energy Facilities Siting Board, and the Massachusetts Environmental Policy Act Office. Beyond requiring community benefits agreements, the order also mandates that developers mitigate utility costs to consumers, prohibits the use of nondisclosure agreements, and requires various state agencies to develop measures to limit data center impacts on the environment. North Carolina Regulators Decline Approval of Duke Energy Gas Turbine On September 18, 2026, North Carolina Utilities Commission (NCUC) denied Duke Energy’s application for a certificate of public convenience and necessity required to construct a gas-fueled combustion turbine at its Smith Energy Complex in North Carolina. The NCUC objected strongly to the $584 million price tag and noted that Duke appeared to be constructing the facility “based on anticipated data center customer additions.” The NCUC rejected that anticipated growth as “insufficiently reliable for the Commission to act at this point.” In rejecting Duke’s application, the NCUC also noted that Duke had signed the White House Ratepayer Protection Pledge, in which it represented that it would not shift data center costs to consumers. The NCUC observed that the record did not demonstrate how Duke “intends to adhere to its commitments under the Ratepayer Protection Pledge with regard to the Proposed Facility.” Notably, commission staff had actually supported the construction of the turbine, citing concerns about Duke’s reserve margins. The NCUC noted that it “understands the Public Staff’s expressed concerns,” but those concerns were outweighed by the NCUC’s reservations, including questions of demand. Department of Energy Approves Funds for Grid Improvement The U.S. Department of Energy (DOE) recently announced that it would fund 31 grid-improvement projects in 26 states. The funding initiative is part of the DOE’s “SPARK” initiative. The funding will include $1.9 billion in federal funding from DOE and $3.35 billion in recipient cost-sharing funding. The funds will go to projects designed to improve grid reliability and lower electricity costs. Recipients plan to reconductor over 1,500 miles of transmission lines and will deploy grid-enhancing technologies across approximately 21,000 miles. DOE stated that this initiative will make available over 23 additional gigawatts of electricity. Texas Moderates Rules Governing Data Center Interconnection The Texas Public Utility Commission adopted new regulations governing large-load interconnections. The rules impose a flat study fee of $100,000 for all proposed interconnections, which departs from the initial proposal to impose study fees using a tiered system based on project size. Additionally, the final rule eliminates the PUC’s previous proposal to impose a non-refundable interconnection fee of $50,000 per MW of contracted peak demand. The final rule also moderates the initially proposed regulations governing Electric Reliability Council of Texas (ERCOT) notifications for large-load customers’ non-utilized capacity. The proposed rules would have required notifying ERCOT within 30 days of missing a scheduled energization milestone by six months. The final rules, however, do not require informing ERCOT unless a scheduled energization milestone is missed by 24 months. FERC Denies TransAlta 202(c) Cost-Recovery Plan The Federal Energy Regulatory Commission (FERC) recently rejected TransAlta’s plan to recover $19.9 million in expenses stemming from a DOE order in which DOE prohibited TransAlta from retiring its coal-powered Centralia power plant. TransAlta had previously intended to retire the facility at the end of 2025. TransAlta’s cost recovery plan proposed spending an additional $23 million on repairs to continue operating the unit. FERC’s main objection had to do with geographic scope. TransAlta’s recovery plan called for recovering costs from California Independent System Operator (CAISO) and the Southwest Power Pool (SPP), but the DOE’s order requiring operation of the plant was designed to ensure reliability in the Northwest assessment area (Montana, Oregon, Washington, and parts of northern California and northern Idaho). Accordingly, FERC was unwilling to allow cost recovery from CAISO and SPP when the order that precipitated the additional costs only related to the Northwest assessment area. FERC informed TransAlta that it would only approve cost recovery from load-serving entities in the Northwest assessment area. FERC’s decision comes amid a rush of DOE emergency orders requiring the continued operation of coal-fired generating units. Litigation Appeals Court Upholds Washington Hydropower Plant With Caveats In a September 21, 2026, opinion, the Washington Court of Appeals largely upheld a Clean Water Act water quality certification by the Washington Department of Ecology for the Goldendale Energy Storage Project, a proposed pumped-water storage hydropower system adjacent to, but off-stream from, the Columbia River. A nonprofit (Columbia Riverkeeper) and the Confederated Tribes and Bands of the Yakama Nation appealed the certification, contending that it failed to impose necessary conditions and monitoring requirements to protect the water quality of the Columbia River. Most saliently, the plaintiffs argued that the project had the potential to leak 100 acre-feet of water per year into tributaries of the Columbia River. The Court of Appeals broadly rejected plaintiffs’ challenge to the state’s conclusion that “the project was designed not to leak.” That said, the Court of Appeals did reverse on one narrow issue. Specifically, the court determined that the state’s conclusion that “leakage from the project’s tunnels would be monitored and reported” was not supported by the evidence because the certification “does not explicitly require monitoring and reporting to determine whether there is any leakage.” Accordingly, the court remanded the matter to the state to impose monitoring and reporting requirements but otherwise affirmed the certification. Legislative Developments California Legislates Restrictions on Data Center Energy Use and Grid Costs On September 21, 2026, California Governor Gavin Newsom signed seven bills broadly regulating data centers in the state. SB 1168 directed the California Public Utilities Commission to assess the energy used by data centers. It also requires the PUC to pass costs of transmission and distribution upgrades and load increases on to data centers, rather than customers. SB 886 and SB 887 compel data centers to pay for infrastructure upgrade and generation costs, and wildfire mitigation costs, in addition to imposing environmental review. The statutes additionally increase local oversight of data centers. AB 1577 imposes a monthly reporting requirement that requires data centers to supply energy consumption and efficiency data to the California Energy Commission. AB 2383 contains incentives for data centers to use onsite clean energy generation. Finally, AB 2469 and AB 2619 require data center developments to assess water supply and develop a water scarcity plan. The statutes also mandate statewide water reporting as a precondition to obtaining and renewing business licenses.

Insights

The Supreme Court Update - October 8, 2026

On September 29, 2026, the Supreme Court granted certiorari in one case: Department of Homeland Security v. D.V.D., No. 26-426: This case concerns the Trump Administration’s “third-country removal” procedures, where immigrants are deported to countries not listed in the removal orders. In granting certiorari, the Court granted the Government’s application to stay a lower court decision halting the practice, which will allow third-country removals to continue pending resolution of the case. The issues presented are: (1) Whether the district court had jurisdiction over respondents’ claims; (2) whether the district court had authority to enter class-wide declaratory relief and APA vacatur under 8 U.S.C. § 1252(f)(1); (3) whether the Government’s guidance on third-country removals is unlawful under 8 U.S.C. § 1231(b), the due process clause, or FARRA/CAT and its implementing regulations; and (4) such other questions that the Government determines are appropriate for the proper disposition of the case. On October 1, 2026, the Court granted certiorari in three additional cases: Rhoney v. Barbosa da Cunha, No. 26-104: Immigration officials detained Ricardo Aparecido Barbosa da Cunha—a Brazilian citizen who had lived in the United States for approximately twenty years after entering without inspection—and denied him a bond hearing under 8 U.S.C. § 1225(b)(2)(A). The Second Circuit held that his detention was instead governed by § 1226(a), which permits release on bond, because § 1225(b)(2)(A)’s mandatory-detention requirement applies only to noncitizens apprehended while entering the country or shortly thereafter. The question presented is: Whether 8 U.S.C. § 1225(b)(2)(A) mandates the detention pending removal proceedings of aliens who, like Barbosa da Cunha, are present in the United States without having been admitted. Missionaries of St. John the Baptist, Inc. v. Frederic, No. 25-113: A Catholic religious organization sought to build a shrine to the Virgin Mary on land the organization owned adjacent to its church in Park Hills, Kentucky. Local zoning restrictions prohibited the proposed construction. The question presented is: Whether a land-use regulation that prohibits a religious institution from building a religious structure on its own property constitutes a “substantial burden” on religious exercise under the Substantial Burden Provision of the Religious Land Use and Institutionalized Persons Act, 42 U.S.C. § 2000cc(a). Marschner v. Marschner, No. 25-1349: Under the Uniformed Services Former Spouses’ Protection Act (“USFSPA”), a veteran’s longevity-based retirement pay can be divided in a divorce, but retirement pay based on disability and retirement pay that was waived to receive disability pay are indivisible. The question presented is: Does the USFSPA require state courts to refuse enforcement of indemnification provisions in a divorce settlement agreement?