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Sarah Grey is nationally-recognized for her work on energy transition, decarbonization, and climate change policy and regulation. She counsels and advocates for a wide array of clients in the energy, liquid fuels, climate tech, manufacturing, and agricultural sectors on regulatory, policy, litigation, and compliance matters related to the federal Renewable Fuel Standard, California's Low Carbon Fuel Standard, the Clean Air Act (CAA), and other state and international initiatives on transportation sector greenhouse gas emissions. Sarah is a leading strategic advisor on carbon capture, storage, and utilization (CCUS) and other energy transition related opportunities, including mandatory and voluntary carbon credit markets and tax credits under the Inflation Reduction Act. She has deep technical expertise on the science of climate change. Sarah also advises clients on climate risk analysis, green marketing claims, and disclosure, among other ESG issues. She frequently represents clients in the fuels, energy, automobile, and manufacturing industries before the Environmental Protection Agency, federal appellate courts, and state environmental and climate regulators. 

Sarah's background includes serving as regulatory counsel for the world’s largest biofuels company and its industry trade association, where she managed regulatory, litigation, and legislative matters related to renewable fuels production and clean energy incentives. She also supported the environmental and permitting teams for over 25 facilities, which included negotiating consent decrees and addressing Clean Air Act information requests and notices of violations.

Experience

  • Major energy company in implementing its domestic CCUS business including completing comprehensive evaluations of regulatory and statutory frameworks in U.S. jurisdictions for CCUS, advising on CCUS leasing, storage, and transportation agreements, and legislative advocacy at the federal and state level.
  • Carbon dioxide removal company in negotiating voluntary carbon credit offtake agreements and navigating related commercial opportunities. 
  • Clean energy producer and CCS storage facility operator in providing strategic guidance on 45Q, 45Z, 45V stacking and eligibility.
  • Multinational energy company in providing advice regarding California's new voluntary carbon credit market disclosure law, AB 1305.
  • NGO in regulatory and environmental analysis of siting projects for solar and wind developments in Colorado.
  • Renewable fuel company on a first-of-its-kind CCUS project that involved novel permitting issues under state law and with respect to grant funding opportunities under state law.

Perspectives

IRS and Treasury Department Issue Final Rules on Transfers of Clean Energy Tax Credits
Advisory
White House and Federal Agencies Issue Principles for Voluntary Carbon Credit Markets
Environmental Edge: Climate Change & Regulatory Insights
ESG Series: Part V: Navigating the Web of Climate and Sustainability Disclosure Requirements: California, EU, and SEC Frameworks
Arnold & Porter Webinar
Climate Change in 2024: Inflation Reduction Act and Other Key Developments
Panelist, American Law Institute Continuing Legal Education and Environmental Law Institute Webcast
EPA Approves Class VI Primacy in Louisiana
Environmental Edge: Climate Change & Regulatory Insights
More

Recognition

Chambers USA
"Up and Coming" Climate Change (USA) (2023-2024)
Best Lawyers
"Ones to Watch" Environmental Law (CO) (2023-2024)
Denver Business Journal
40 under 40 (2023)
More

Credentials

Education

  • J.D., Stanford Law School, 2011
  • M.S., Environment and Resources, Stanford University, 2011
  • B.A., University of Virginia, 2007, with honors

Admissions

  • Colorado
  • California
  • U.S. Court of Appeals for the Fourth Circuit

Clerkships

  • U.S. District Court, Eastern District of Virginia, The Honorable Rebecca Beach Smith

Activities

  • Advisory Board Member, Institute for Energy Law (2022–present)
  • City Year Denver Board Member (2023–present)
  • Colorado General Counsel Diversity Mentoring Program (2019–2022)
  • Environmental Law Institute, Emerging Leaders Initiative (2021)
  • Vice Chair, Programs, American Bar Association Section of Environment, Energy, and Resources (SEER), Air Quality Committee
  • Planning Committee Member, SEER Fall 2020 Conference
  • Participant, American Bar Association SEER Leadership Development Program (2018–2019)
Overview