Sarah Grey counsels a wide array of clients on regulatory, policy, and compliance matters related to climate change, including the federal Renewable Fuel Standard (RFS), California's Low Carbon Fuel Standard (LCFS), the Clean Air Act (CAA), and other state and international initiatives on transportation sector greenhouse gas (GHG) 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 (IRA). She has deep technical expertise on GHG lifecycle accounting and fuels regulatory, compliance, and litigation matters, including enforcement defense matters. Sarah also advises clients on climate risk analysis and disclosure and other environmental, social, and governance (ESG) issues. She frequently represents clients in the fuels, energy, automobile, and manufacturing industries before the Environmental Protection Agency (EPA) and California regulators. 

Sarah's background includes serving as regulatory counsel for a large biofuels company and its industry trade association, where she managed regulatory, litigation, and legislative matters related to renewable fuels production and regulatory 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.

While at Stanford Law School, she served as Editor-in-Chief of the Stanford Environmental Law Journal.

Experience

  • Major energy company in implementing its domestic CCUS business including completing comprehensive evaluations of regulatory and statutory frameworks in US jurisdictions for CCUS, advising on CCUS leasing, storage, and transportation agreements, and legislative advocacy at the federal and state level.
  • Major refiners in defense of EPA enforcement actions concerning RFS and fuel quality regulations.
  • Large biofuel company in assessing 45Q tax credit eligibility and LCFS credit generation, compliance, and risk mitigation under the LCFS’s CCS Protocol.
  • Major renewable fuels manufacturer before EPA on regulatory issues under the RFS, and litigation concerning same.
  • Major renewable fuels trade association related to tax credits and other opportunities under the Inflation Reduction Act.
  • Fortune 100 company in connection with environmental risk assessment, remediation of contaminated sites, and real estate transactions.

Perspectives

Green Marketing Claims: What Your Company Needs to Know
Environmental Edge: Climate Change & Regulatory Insights
EPA Announces New Enforcement Priorities on Climate Mitigation and PFAS; Solicits Public Comment and Recommendations
Environmental Edge: Climate Change & Regulatory Insights
What Your Company Needs to Know Regarding Green Marketing
Arnold & Porter Webinar
FTC Seeking Comments on Green Guides; May Seek to Convert to Binding Regulation
Environmental Edge: Climate Change & Regulatory Insights
FAR Council Proposes Climate Change Policy Including Inventory and Disclosure of Greenhouse Gas Emissions and Science-Based Targets
Environmental Edge: Climate Change & Regulatory Insights
More

Credentials

Education
  • JD, Stanford Law School, 2011
  • MS, Environment and Resources, Stanford University, 2011
  • BA, University of Virginia, 2007, with honors
Admissions
  • Colorado
  • California
  • District of Colorado
  • US Court of Appeals for the Fourth Circuit
Clerkships
  • US District Court, Eastern District of Virginia, The Honorable Rebecca Beach Smith
Activities
  • Advisory Board Member, Institute for Energy Law (2022–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

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