Sidley has decades of experience advising clients on federal and state regulatory fuels compliance, enforcement, transactional advice, advocacy, and litigation under the EPA’s Renewable Fuel Standard (RFS) and other fuel regulatory programs.
Fuels Regulation and Enforcement
We have a deep bench of lawyers who frequently advise clients on RFS issues, including compliance counseling, transactions, and RFS reform. We provide similar support to clients on Low Carbon Fuel Standard (LCFS) developments, credit trading provisions, and compliance. We also regularly engage with the relevant agencies — the EPA, the Department of Energy, the Department of Agriculture, and the California Air Resources Board — on these topics. In addition, we advise our clients on preemption issues that arise between California and the federal government (the EPA and the National Highway Traffic Safety Administration (NHTSA)) with respect to carbon emissions regulations.
Sidley has served as counsel for the major litigation in this space, including the litigation challenging the California LCFS under the Commerce Clause and the current litigation regarding the EPA’s and NHTSA’s revocation of the California light-duty waiver.
Sustainable and Alternative Fuels
Sidley has a market-leading SAF practice, guides clients on M&A and transactional matters, and provides advisory services and regulatory counseling.
Sidley has extensive experience in the development of the sustainable fuels and biofuels sector. We work across the supply chain in a wide variety of industries on production, distribution, and storage projects involving sustainable fuels, biofuels, and hydrogen. We regularly advise clients on decarbonizing their operations, investments in early- and mid-stage technology development companies, project development, offtake, and purchase agreements, and the development of strategic alliances for the purpose of fostering cutting-edge technologies.
At the forefront of the energy transition and clean technology revolution, we guide clients investing in and developing new environmentally sustainable products, renewable technologies, and solutions through an expansive array of financing, technology transactions, and regulatory matters.
Sidley has assisted clients with numerous groundbreaking projects and transactions, including the largest sustainable fuel purchase agreement in aviation history, first of their kind CCUS projects, sustainable fuel from forest and crop waste and other biomass, electric and hydrogen-powered vehicles, the development of the first supersonic aircraft designed to use sustainable fuel, and short- and medium-length passenger drones.
