Climate Policy News You Can Use — December 2023

Dear Colleagues,

The EDF team recently returned from COP28, which brought important progress including a pledge by 50 oil and gas companies to cut methane emissions up to 80-90% (see EDF’s statement) and the launch of the Dairy Methane Action Alliance. Still, much more needs to be done to ensure a fast, just and equitable transition to clean energy. Read on for key policy developments and advocacy opportunities in the U.S., and a personal update from me at the end.


Methane rules are here!

EPA released its long-awaited methane rules for new and existing oil and gas facilities on December 2nd (see EDF’s blog). These urgently needed requirements are the culmination of a years-long stakeholder process that resulted in historic support from companies across sectors. (Note: methane rules are relevant not just to oil and gas companies but also to banks and investors, electric utilities, companies that use natural gas as a manufacturing input, and major electricity users in states with gas-heavy grids.) Now is the time to celebrate this milestone in methane policy!


CBAM proposals gain traction on Capitol Hill

Senator Whitehouse and Representative DelBene reintroduced the Clean Competition Act (S. 3422), which would establish a carbon border adjustment alongside a domestic performance standard to cut GHG emissions. The Clean Competition Act can create a race to the top among global competitors as part of a larger effort to move toward a low-carbon economy, while opening a dialogue about additional efforts needed to address local pollution impacts on frontline communities. See EDF’s statement.

  • Take Action:
    • Urge policymakers to:
      • Integrate local air quality projections alongside greenhouse gas reductions in the policy design.
      • Adhere to the Biden administration’s Justice40 goals of ensuring that at least 40 percent of the benefits of any CBAM proposal go to frontline communities.
    • Reach out to Andrea Pereira ( if your company is interested in CBAMs.


FERC to finalize Transmission Planning and Cost Allocation rule

Stakeholders are increasingly calling on the Federal Energy Regulatory Commission (FERC) to finalize the Transmission Planning and Cost Allocation reforms it proposed in April 2022. These reforms are essential to accelerate the deployment of clean energy, increase grid reliability, prepare for increased electrification of vehicles and buildings, and realize the potential emission reductions from the Inflation Reduction Act. Check out new letters from environmental NGOs (including EDF) and a cross-sector coalition including utilities, labor, and other energy businesses.

  • Take Action:
    • Reach out to FERC directly and/or issue a public letter urging FERC to finalize a strong Transmission and Cost Allocation rule as early as possible in 2024.


SEC to release final rule on climate disclosure

The Securities and Exchange Commission (SEC) is preparing to issue its final rule on climate-related financial disclosure in early 2024. The rule will bring disclosure of climate risk level with other forms of financial risk, enabling prudent decision-making by companies and investors. It is vital for organizations that support climate disclosure to publicly welcome the final rule upon its release.

  • Take Action:
    • Prepare to make a positive statement on the release of the SEC’s final rule. If you filed supportive comments with the SEC, reiterate the points of your letter publicly.
    • Work with other companies and your industry groups to show support for the final rule.


In other news: IRA, SCOTUS and me

The Inflation Reduction Act is driving record investment in clean energy: see this report and White House blog. Maintaining the momentum, Treasury released proposed guidance for the Section 45X Advanced Manufacturing Production Credit that has already spurred $140B in private-sector investment since the IRA was passed. Note: if you’d like to stay up-to-date on IRA implementation guidance, check out and subscribe to get weekly updates by email.

In a welcome decision last week, the U.S. Supreme Court declined to hear challenges to EPA’s Clean Air Act responsibility to address climate pollution. EDF was a party to the case and submitted a brief along with other environmental and public health groups. strongly defending EPA’s science-based determination of the Endangerment Finding. See EDF’s statement.


Finally, my news: I will be moving on from EDF at the end of this week. The last 26 years have been an amazing journey, and it’s been an honor to work alongside colleagues and partners dedicated to addressing the climate crisis. I am looking forward to taking some time off and exploring new ways to have an impact. Andrea Pereira and Daniel Neff (both cc’d) will carry forward EDF’s corporate engagement on climate policy. If you have not connected with them or want to talk 2024 policy priorities, please reach out!

To everyone working to secure the policies we need to keep a 1.5-degree future within reach: you have my unending gratitude, appreciation and encouragement. I wish you all a peaceful holiday season and a great start to the new year!