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Sarah Grey is nationally-recognized for her work on climate change policy and regulation, counseling a wide array of clients in the energy, liquid fuels, climate tech, manufacturing, and agricultural sectors. She has a leading practice in the renewable fuels and climate regulatory space, with deep expertise on compliance, litigation, and policy 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 (GHG) emissions and cap-and-invest programs. Sarah frequently represents clients before the Environmental Protection Agency, the California Air Resources Board, federal appellate courts, and state environmental regulators in enforcement proceedings, audit responses, and regulatory disputes — including multimedia audits and enforcement cases arising from those audits.

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 also regularly guides companies in the energy transition space on transactional and commercial arrangements, crafting creative solutions to mitigate risk and optimize value.

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

But Wait, There’s Less! Science in Rulemaking: Navigating Challenges and Innovations
55th Spring Conference on Environmental Law
Disputes Impacting Deployment of Low Carbon Technologies
5th Annual Texas Symposium on Climate Change and Energy Transition at EarthX2026
Energy and Energy Transition
Western Boot Camp on Environmental Law® 2026 | Environmental Law Institute
State, Federal Policies Complicate Fuel and Carbon Markets (pdf)
Law360
Bloomberg Law Quotes Sarah Grey on IRS Proposal Clarifying Clean Fuels Tax Credit
Bloomberg Law
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Recognition

Chambers USA
"Up and Coming" Climate Change (USA) (2023-2025)
Best Lawyers
"Ones to Watch" Environmental Law (CO) (2023-2025)
Denver Business Journal
40 under 40 (2023)
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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)
Overview