.

Jamie represents a variety of corporate finance clients in finance transactions and debt restructurings.

She represents financial institutions, private equity funds, mezzanine funds, agent banks, institutional investors and startup companies in finance transactions and debt restructurings. Her experience includes both senior and subordinated debt transactions, leveraged buyouts, second lien financings, unitranche financings, cash flow and asset-based financings, equipment financings, project financings, structured financings, health care financing and real estate financings. She also has extensive experience in workouts and restructurings.

Jamie has handled corporate transaction matters across a wide range of industries, including energy, financial services, manufacturing, telecommunications, technology, transportation, insurance, retail, health care, construction, restaurant and hospitality.

Jamie also serves on Dorsey’s Management Committee.

Select Experience

  • Represented the term lender in a $110 million unitranche facility to a public company borrower in a global marketing services firm.
  • Represented agent in a $45 million syndicated loan facility to a borrower in the weight loss industry.
  • Represented the subordinated lender in a notes offering to a borrower in the dermatology industry.
  • Represented the senior lender in a $305 million asset-based financing provided to a borrower in the gas compression industry.

Education

  • Baylor University School of Law (J.D., 2000)
  • Baylor University (B.B.A., Marketing and Management, 1997)

Bar Admissions

  • Texas

Accolades

  • Best Lawyers in America®, Banking and Finance Law, 2021-2026
  • Texas Rising Star Thomson Reuters' Texas Super Lawyers, 2005-2008

Insights

Articles

What to do if your PPP loan isn’t forgiven

May 3, 2021

Client Alert

Round Three of the PPP—The New Stimulus Bill Amendments

January 5, 2021

In an effort to achieve an agreement before the expiration of many of the CARES Act1 economic relief measures, on December 21, 2020, the U.S. Congress passed the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (the “Act”). The Act is included as Title III of the approximately 5,500-page Consolidated Appropriations Act, 2021 (the “Appropriations Act”), which adopts numerous stimulus and economic assistance provisions across a wide range of organizations and entities operating within the U.S. economy. The president signed the Appropriations Act (including the Act) into law on December 27, 2020. This Alert is an initial analysis of the expanded Paycheck Protection Program (the “PPP”) — which was a material component of the CARES Act. The PPP was a novel policy tool when launched and proved to be an enormously popular one. When the initial $349 billion appropriated to the program was exhausted in a matter of days, Congress added $320 billion to the program through the Paycheck Protection Program and Health Care Enhancement Act adopted on April 24, 2020.2 Appropriated but unused funds from those earlier authorizations have been made available for the PPP loans authorized under the Act.3 The Act extends and continues the origination authority for the existing PPP from August 8, 2020 until March 31, 2021, with slightly modified rules for loan applications and loan forgiveness. In addition, the Act creates a new second draw program (the “Second Draw PPP”) for smaller eligible entities (e.g., with 300 or fewer employees and a maximum loan amount of $2 million). Among other things, the Second Draw PPP will be available for borrowers under the original PPP (the “Original PPP”), provided that a smaller eligible entity has repaid its Original PPP loan. Perhaps a result of the frenetic negotiations that are not unusual in contentious congressional compromises, the Act’s 48 separate provisions are not well organized, and in many cases are opaque in intent and meaning. To help guide an initial review and analysis of the amendments to the PPP, we have organized the Act’s provisions into the following categories: (a) the extension of the Original PPP; (b) the Second Draw PPP; (c) PPP small borrower provisions and enhancements; (d) PPP loan processing and administrative provisions; (e) lender liability protections; (f) miscellaneous provisions; and (g) SBA requirements, the effective date of the Act and the issuance of SBA regulations and guidance. The Extension of the Original PPP Program Despite criticism of the availability of the PPP to entities not needing federal assistance caused by the pandemic, the Original PPP remains essentially intact. Persons and entities that have failed to obtain a PPP loan prior to August 8, 2020 may once again apply for a PPP loan.4 As discussed below, except for: (a) prohibiting SEC-registered companies from obtaining a PPP loan; and (b) minor adjustments in regard to the loan application and loan forgiveness processes, businesses with 500 or fewer employees will continue to qualify for funding up to an amount not exceeding $10 million.5 The PPP Second Draw Program The Act authorizes a new PPP loan program, the “Second Draw PPP,” which authorizes the origination of new PPP loans to smaller businesses in a maximum amount of $2 million.6 The Second Draw PPP reflects the intent to emphasize economic relief for smaller, local businesses. In order to receive a Second Draw PPP loan, an eligible business must: Employ not more than 300 employees Have used or will use the full amount of its Original PPP loan, if applicable, and Demonstrate at least a 25 percent reduction in gross receipts calculated based upon first, second or third quarters of 2020 as compared to 2019.7 Eligible persons and entities under the Second Draw PPP are as follows: Businesses Certain nonprofit organizations Housing cooperatives8 Veterans’ organizations Tribal businesses Self-employed individuals Sole proprietors Independent contractors, and Small agricultural cooperatives.9 The Second Draw PPP permits most eligible borrowers to receive a loan amount of the lesser of up to 2.5 times its average monthly payroll or $2,000,000, provided that a maximum employee loan limit is now set at 300 employees including affiliates (but eligible businesses with NAICS code 72 (Accommodations and Food Services) having more than one location may have up to 300 employees per location). Importantly, the Act specifies that a Second Draw PPP loan may only be made to an eligible business that: (a) has previously received an Original PPP loan; and (b) has used 100% of the proceeds of the Original PPP loan before the Second Draw PPP loan proceeds are disbursed.10 Only one Second Draw PPP loan may be obtained by an eligible borrower.11 An important exception to the general rule on the maximum loan amount calculation applies to entities in industries assigned to NAICS code 72 (Accommodations and Food Services), which entities may receive loans of up to the lesser of $2 million or 3.5 times their average monthly payroll costs. Permitted expenses that may be forgiven under the Second Draw PPP include the same permitted expenses under the Original PPP (i.e., defined payroll costs12, as well as covered mortgage, rent, and utility payments), but also now include covered operations expenditures, covered property damage costs, covered supplier costs, and covered worker protection expenditures incurred during the covered period.13 Smaller Borrower PPP Provisions The Act contains useful improvements for processing smaller Second Draw PPP loans, which the Act defines as a Second Draw PPP loan in an amount of $150,000 or less. In that regard, the Act creates an expedited loan application and certification process for PPP loans not exceeding $150,000—which must include a one-page certification form to be created by the SBA for use at the time of loan application.14 Significantly, a borrower seeking loan forgiveness for a PPP loan not exceeding $150,000 is not required to submit additional documentation supporting the new short-form certification (except in the case of the applicability of another federal or state law or audit requirement). In addition, the mandatory documentation language in the CARES Act for smaller PPP loans of $150,000 or less was amended to allow the SBA greater flexibility to determine documentation when determining eligibility.15 Administrative and PPP Loan Processing The Act clarifies many existing PPP loan rules and adopts changes that industry participants have criticized as impediments to the efficient operation of the PPP. For the Second Draw PPP, the Act establishes a three-tiered structure for lender compensation for PPP loans originated after the effective date of the Act: For loans up to $50,000, the processing fee is set at the lesser of 50 percent of the principal loan amount or $2,500 For loans between $50,000 and $350,000, the processing fee is set at five percent of the principal loan amount, and For loans above $350,000, the processing fee is set at three percent of the principal loan amount.16 As noted above, the Act expands on the categories of forgivable business-related expenses under the PPP, and now includes: Payments for any software, cloud computing, and other human resources and accounting needs Certain property damage costs relating to property damage due to public disturbances that occurred during 2020 that are not covered by insurance Specified supplier costs that are essential to a business’ operations, including costs incurred during (or prior to) the covered period of a PPP loan that are essential to the recipient’s operations at the time the expenditure was made, and Covered worker protection expenditures, including capital expenditures, personal protective equipment and adaptive investments intended to comply with state and federal health and safety guidelines relating to COVID-19.17 The Act attempts to correct certain origination problems experienced by borrowers and lenders under the Original PPP. Among other things, the Act, together with the Appropriations Act: Exempts loan forgiveness under the PPP from inclusion in ordinary income of a PPP borrower18 Allows a borrower to elect a covered period ending at the point of the borrower’s choosing—between 8 and 24 weeks after origination19 Expands the seasonal period for calculation purposes to any 12-week period between February 15, 2019 and February 15, 202020 Clarifies that the interest rate on all PPP loans is non-compounding and non-adjustable21 Repeals a provision in the CARES Act that required recipients of a PPP loan to deduct the amount of any EIDL loan from the PPP loan forgiveness amount22 Prohibits publically traded companies from obtaining PPP loans23 Extends the covered period for the PPP through March 31, 2021 (which provides additional flexibility for a PPP borrower when utilizing PPP funds for approved costs and expenses)24 Clarifies the applicable period for employees’ salaries of $100,000 on an annualized basis as prorated during the period in which compensation is paid or incurred,  and25 Clarifies that a business or organization that was not in operation on February 15, 2020 is not eligible for either a PPP loan under the Original PPP or the Second Draw PPP.26 Lender Liability Protections Based upon thinly veiled threats by the SBA in the past several months to take possible enforcement action against PPP lenders, the Act contains welcome statutory liability protections for the lender community, as follows: PPP Lender Hold Harmless—Notwithstanding clear language in regard to the limited obligations of a lender when processing a PPP loan, the SBA and Treasury have previously issued statements that could be interpreted as potentially creating lender liability for errors or fraud in the PPP origination and loan forgiveness processes. The Act substantially resolves these concerns by stating that the government cannot take enforcement action, including the imposition of penalties, against a PPP lender when the lender reasonably relies upon any certification or documentation submitted by a borrower. The standard for liability protection is that: (a) the lender acted in good faith when complying with its obligations regarding the loan origination or forgiveness processes; and (b) all relevant federal, state, local and other statutory and regulatory requirements were satisfied.27 Lender Bankruptcy Code Protections—In light of the experience by the PPP lender community that many PPP borrowers have been forced to seek bankruptcy protection, in order to afford additional protection to taxpayers and participating PPP lenders, the Act grants a lender a superpriority claim in the bankruptcy process when a PPP loan is obtained following the filing of a bankruptcy petition.28 Miscellaneous The Act contains numerous special provisions for both individuals and groups, and addresses unique circumstances not necessarily applicable to all participants in the PPP in general. These provisions include, among others: Farmers and Ranchers—The Act authorizes a special calculation of the maximum loan amount for certain farmers and ranchers who operate as sole proprietors, independent contractors and self-employed individuals29 Conflicts of Interest—The Act: (a) clarifies the applicability of conflict of interest rules for borrowing entities owned or partially owned by certain senior federal officials; (b) prohibits the origination of new PPP loans to a covered entity (i.e., an entity that is owned in whole or in part by a senior federal official); and (c) requires a covered entity to identify itself to the SBA when it applies for loan forgiveness30 Shuttered Venue Operators—The Act authorizes $15 billion for the SBA to make grants to eligible live venue operators or promoters, theatrical producers, live performing arts organization operators, museum operators, motion picture theatre operators, or talent representatives who demonstrate a 25 percent reduction in revenues in 2020 (or 2021) when compared to the same quarter in 2019.31 These provisions—which are non-credit grants of operating funds—are intended to address a critical need to maintain the operational capability for the performing arts and related entities. The Act prohibits eligible entities that receive a grant under the Shuttered Venue Operator Grants program from obtaining a Second Draw PPP loan32 Farm Credit Institutions—The Act authorizes institutions operating under the Farm Credit Act of 1971 to originate PPP loans33 CARES Act Waiver—The Act extends the CARES Act waiver for Women’s Business Center matching funds through June 30, 202134, and Modifications to Other SBA Loan Programs—In addition to the modifications made to the operation of the PPP, the Act makes numerous amendments to other smaller loan amount SBA programs, including, among others, the Section 7(a) lending program, the EDIL program, the Section 504 program and the Community Advantage and the Microloan programs, and increases the amount of funds available under these loan programs, provides for the resumption of payments of principal and interest by the SBA on qualifying loans under these sections for between three and eight months, and homogenizes many of the operating requirements of these programs with those of the PPP. SBA Requirements, the Effective Date of the Act and the Issuance of SBA Regulations and Guidance The provisions of the Act are effective as of December 27, 2020 (i.e., the date the president signed the Appropriations Act).35 However, the Act states that the SBA must issue regulations no later than 10 days following the effective date of the Act, and waives certain notice and comment requirements of the Administrative Procedure Act.36 The Act contains typical instructions that are directed to a federal agency responsible for implementing a new or revised statute, such as complying with GAO oversight requests, etc. Though the SBA is capable of issuing an initial set of regulations within the 10-day time period, it is likely that a fulsome regulatory process may require additional time to complete. Among other things, integrating the Second Draw PPP authorities into the existing PPP regulatory structure will be complicated. For example, the Act contains numerous provisions that: (a) applies the new PPP rules to Original PPP application and loan forgiveness rules; (b) applies some of the new PPP rules to Original PPP loans, but only to the extent the loan has not been forgiven; and (c) excludes from coverage Original PPP loans to the extent they have been forgiven. At a minimum, PPP lenders should insist that the SBA provide clear interpretative guidance in regard to the integration of the operational requirements of the Original PPP and the Second Draw PPP.37 Moreover, new forms and certifications will have to be drafted and promulgated by the SBA, as well as directions for processing Second Draw PPP loans and the PPP loan forgiveness process. *       *       * When reviewing this Alert, please note that hurriedly negotiated compromises such as the Act may frequently include either errors in drafting or intent (or both).  Accordingly, additional guidance regarding the scope of the Act may be forthcoming in the next several weeks—particularly from the SBA. Dorsey attorneys are available to provide updates as they become available. 1 Public Law No. 116-136 (March 2020). 2 Public Law No. 116-139 (April 2020). 3 Section 323 of the Act. An aggregate amount of $806.5 billion has been appropriated; of that amount, several SBA programs other than the PPP have been allocated additional funds (e.g., set-asides) within that aggregate amount. 4 Section 342 of the Act. 5 Many of the adjustments to the PPP terms and conditions applicable to the Original PPP are discussed below and will likely require the SBA to modify its PPP regulations and guidance documents. For example, the SBA has announced its intention to analyze new applications for an Original PPP loan through an improved web portal prior to approving the same. 6 Section 311 of the Act. 7 Note that this requirement appears to be an attempt to eliminate otherwise eligible borrowers that have not experienced demonstrable economic loss as a result of the pandemic from participating in the PPP. Additional calculation flexibility is provided for eligible entities not in operation in 2019. 8 Section 316 of the Act. 9 Section 311 of the Act. Ineligible entities include entities listed in the SBA’s regulations at 13 C.F.R. 120.110, except for entities included in that regulation that have otherwise been made eligible by statute or guidance, such as certain nonprofits and religious organizations. In addition, certain other business entities are ineligible, including lobbying organizations, entities representing certain foreign governmental interests (including entities affiliated with entities in the People’s Republic of China), senior federal officials and publically traded companies, as well as recipients of grants under the Shuttered Venue Operators Grant program. 10 Section 311 of the Act. 11 The effect of this limitation is to require that a business that has not previously received a PPP loan must apply and qualify under the Original PPP guidelines. 12 Section 308 of the Act clarifies that employer-provided group insurance benefits are included in payroll costs, including group life, disability, vision, or dental insurance (and applies to PPP loans originated on or before the date of the Act, including loans that have been forgiven). 13 The current 60/40 cost allocation between payroll and non-payroll costs in order to receive full forgiveness will continue to apply. 14 Section 307 of the Act. The SBA has 24 days to draft and promulgate the new certification form. In addition, Section 307 requires the SBA to provide more transparency in respect to the loan forgiveness process for PPP loans exceeding $150,000, including regular reports to Congress. 15 Section 335 of the Act. 16 Section 311 of the Act. Section 340 of the Act contains a slightly different schedule of fees, which applies to the Original PPP for which the SBA has not yet provided reimbursement. Further, the Act also clarifies (in what may be more an aspirational directive than obligation) that lender reimbursement by the SBA for loan origination fees must be made by the SBA no later than five days post-disbursement. 17 Section 304 of the Act. This provision allows loans made under the Original PPP on or after the enactment of the Act to be eligible to utilize the expanded forgivable expenses, except for borrowers who have already had their PPP loans forgiven. 18 Section 248 of the Appropriations Act. The Appropriations Act contains numerous IRS Code modifications, (many of which will be addressed in a separate Dorsey Alert). For example, after the CARES Act was enacted, the Treasury took the controversial position that expenses paid for with PPP loan proceeds could not be deducted from taxable income if the loan was ultimately forgiven. The Appropriations Act makes clear that these expenses are in fact deductible. 19 Section 306 of the Act. 20 Section 336 of the Act. This provision applies to Original PPP loans that have not been forgiven. 21 Section 339 of the Act. 22 Section 333 of the Act. This provision appears to be retroactive, and permits an Original PPP borrower to now receive as part of loan forgiveness the amount of an EIDL loan that was deducted from the Original PPP loan forgiveness calculation. 23 Section 342 of the Act. 24 Section 343 of the Act. The extension of the covered period may practically delay the filing of numerous applications for PPP loan forgiveness until the second quarter of 2021. 25 Section 344 of the Act. 26 Section 310 of the Act. 27 Section 305 of the Act. The language of Section 305 states that this limitation of liability is retroactive to apply to Original PPP loans in addition to Second Draw PPP loans. 28 Section 320 of the Act. In order for these bankruptcy protections to become effective, the SBA is required to issue a written determination to the Director of the Executive Office of the United States Trustees that, among other things, establishes eligibility requirements for obtaining a PPP loan. This authority will expire two years from the effective date of the Act. 29 Section 313 of the Act. The language of this provision implies that covered farmers and ranchers with PPP loans may be able to increase the amount of the loan based upon this amended calculation (unless the PPP loan has already been forgiven). 30 Section 322 of the Act. 31 Section 324 of the Act. 32 Section 324 also prohibits otherwise eligible grant recipients from participating if is a publically traded company. (Large publically traded movie theater chains and similar large entertainment businesses have been vocally objecting to their exclusion from this grant program based upon this exclusion.). 33 Section 314 of the Act. 34 Section 345 of the Act. 35 Section 348 of the Act. 36 Section 303 of the Act. 37 In addition to the need for lender guidance SBA regulatory guidance will also affect borrowers. For example, to the extent that SBA regulations expand the amount of a PPP loan that is available, Section 312 of the Act permits a borrower to apply for a supplemental loan amount, provided that the PPP loan has not been forgiven.  

Firm Highlights

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

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.

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Dorsey & Whitney Partner Michael W. Droke Releases Fourth Edition of Cooperative Business Law: A Practical Guide with Enhanced Insights for Today's Cooperatives

Industry-leading reference updated with practical tips and current cooperative law developments Dorsey & Whitney LLP is pleased to announce the publication of the fourth edition of Cooperative Business Law: A Practical Guide to the Special Laws Governing Cooperatives, authored by Dorsey Partner Michael W. Droke. Drawing on more than 20 years of direct experience as outside general counsel to major agricultural and food industry cooperatives, Droke has updated this essential resource with new practical tips, real-world guidance, and insights into emerging cooperative law issues that matter to cooperative leaders and their advisors. Since its initial publication, this comprehensive guide has become the standard reference for attorneys, executives, and cooperative governance professionals navigating the unique legal landscape of cooperative organizations. The new fourth edition builds on that foundation by incorporating practical lessons learned from recent cooperative transactions, governance challenges, and regulatory developments. "I am grateful for Dorsey's continued support of this work and for the opportunity to contribute to the cooperative community," said Droke. "Over the past 20 years, I've had the privilege of serving as outside general counsel to some of the nation's most successful cooperatives. The practical insights gained from that work inform every page of this edition. I wanted to create a resource that helps cooperative leaders and their legal advisors tackle real business challenges with confidence." The Fourth Edition features: Practical tips and real-world case examples drawn from decades of cooperative practice Guidance on cooperative formation, governance, member rights, and voting structures Current analysis of antitrust and Capper-Volstead Act issues affecting modern cooperatives Insights into financing, mergers and acquisitions, and corporate restructuring for cooperatives Member relations strategies and dispute resolution approaches specific to cooperative structures About Michael W. Droke Michael W. Droke is a Partner at Dorsey & Whitney LLP and Firmwide Co-Chair of the Food, Beverage & Agriculture practice group. He serves as outside primary counsel for numerous cooperatives, providing comprehensive legal guidance on all aspects of cooperative operations, governance, member relations, corporate restructuring, financing, and mergers and acquisitions. His representative clients include National Co+op Grocers, Darigold, the Northwest Dairy Association, Organic Family Farms Cooperative, Chelan Fruit Cooperative, and Sacramento Natural Foods Co-op. A former business executive who brings a dual perspective to his practice, Droke combines legal expertise with practical business acumen. He has served as an outside board member and general counsel for major cooperatives and maintains deep involvement in the cooperative community through regular presentations and participation in industry organizations including NCBA CLUSA, the National Society of Accountants for Cooperatives, and the National Council of Farmer Cooperatives. About Dorsey & Whitney's Cooperative Law Practice Dorsey & Whitney's Cooperative Law practice group is a recognized national leader in cooperative law with more than 45 years of experience serving agricultural cooperatives, rural electric cooperatives, purchasing cooperatives, consumer cooperatives, worker cooperatives, and cooperative start-ups across the nation. The practice includes 20 dedicated lawyers who advise cooperatives and other agriculture-related organizations on formation and organization, voting rights and governance, antitrust and Capper-Volstead Act compliance, tax issues, project development and finance, mergers and acquisitions, real estate, labor and employment, environmental compliance, and all other aspects of cooperative business operations. Cooperative Business Law: A Practical Guide to the Special Laws Governing Cooperatives, Fourth Edition, is available from major book retailers and online booksellers.

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?