The First 100 Days - Energy transition in a changing regulatory landscape

Speaker A: Hello and welcome to the First Hundred Days, a podcast from Whiten Case that features our lawyers views on the likely regulatory, legal and policy implications of the new administration on businesses operating across the globe and in various industries. I'm Eric Light, a member of the firm's executive committee and a partner in our debt finance practice. Today I'm joined by Taylor Pullens and Hayden Baker. Taylor is a partner in our M and A practice based in Houston who focuses on environmental law and co heads our sustainability and responsible business practice. Hayden is a partner in our M and A practice based in New York and has extensive experience on energy transactions and infrastructure projects. We'll be talking about the new administration's expected approach to the energy transition and its impact on business. Taylor Hayden, can each of you give us just a quick overview of your practice and areas of expertise?

Speaker B: Thank you, Eric.

Speaker C: Uh, my name is Taylor Pullens. I'm an environmental partner located in our Houston office. There are three primary areas of my practice. I work on energy infrastructure projects. Specifically, I work on the environmental permitting and the site development aspects of energy projects. I also work on the management and allocation of environmental risks associated with deals and projects. And this includes risks associated with climate change and society's focus on climate change. And third, I work on additional ways to monetize emissions reduction activities through the generation and selling of carbon removal units, or more commonly referred to as offsets.

Speaker B: Thanks, Eric. I'm Hayden Baker. I'm an M and A partner and I focus as an industry on energy and infrastructure. I uh, typically represent infra funds, strategics and other investors in their investments in companies, platforms, joint ventures, structured equity, as well as portfolios and project investments. And I work across, across a pretty wide range of asset classes including thermal power, renewables, energy storage, energy services, clean fuels, and then newer growth areas like hydrogen and water.

Speaker A: Delighted to have you both here today. Since his inauguration, Trump has taken executive action that reverses, or at least calls into question significant US climate commitments. Some examples include the 90 day freeze on all foreign aid, the rollback of fuel economy standards, and the executive order targeting wind energy and EVs. So what impact do you expect these actions to have on the overall momentum toward the energy transition both in the US and around the world.

Speaker B: So if the question is about overall momentum, I would say these are speed bumps. Some of them are very big ones. But the larger trend toward a lower carbon economy is inevitable. Um, over the next 25 to 30 years, the global economy will reduce greenhouse gas intensity and the industry will for the most part, voluntarily drive that change, not any one government, let alone administration. Um, now that said, in the context of any particular project or financing, yes, these speed bumps can be severe. This executive branch is imposing its will in aggressive ways and breaking with historic norms to do so. Certainly like what we saw with the wind executive order or the pause on Army Corps permitting or looking to halt the rollout of federal, uh, funding, um, these were curve balls and we're helping clients navigate those developments all the time. But good projects, uh, they take time and depending on the asset class, we're talking about 4, 8, 10 plus years for development and then they have useful lives that are decades, you know, 25 to maybe 40 plus years. And so industry investors are planning on a much longer timeline than this four year stretch. And I think that's really useful context when we're thinking about the next few years.

Speaker C: Yeah, Hayden, I agree. Look, we've seen considerable executive action in the last few weeks, um, and several of these executive actions either directly or indirectly affect U.S. climate commitments. We've seen the executive order of withdrawal from the Paris Agreement, an international treaty around climate mitigation at the UN level entered into by a number of countries. And countries have made commitments to combat climate change by reducing global emissions to net zero by 2050. And that certainly has an impact on public, ah, perception of how US Government will incentivize or regulate around climate change activities. This all represents a major policy shift at the federal level. Uh, the previous administration prioritized what they referred to as an all of government approach to combating climate change. And the Trump administration does not believe that many of the climate focused, uh, efforts and priorities under President Biden are in America's best interest.

Speaker A: So where do you see ESG trends headed and how are you positioning yourselves to support clients in these areas?

Speaker C: ESG related investments are not going away. Countries have made nationally determined contributions or NDCs under the Paris Agreement. But countries, they can't achieve the emissions reduction spelled out in an NDC without substantial support by the private sector. The lion's share of emissions do not come from government buildings or government vehicles. In developed countries at least, governments approach their NDCs and the objective of facilitating private sector involvement through regulation. And that regulation can include both or either of a government incentive for emissions reduction or uh, it can include heightened compliance requirements with uh, the threat of civil or administrative penalty if a company doesn't comply with those heightened requirements. So both the carrot and the STIC approach of governing, we've seen companies following up, uh, this government steer whether to seize the opportunity for a tax incentive or some other government funding opportunity, or to comply with increasing regulation. Companies, uh, have made their own commitments. Uh, these commitments include emissions reduction efforts, uh, even net zero commitments and substantial interest from investors has resulted. There are significant push factors toward continued attention and investment in sustainability focused projects and the energy transition.

Speaker A: Broadly, when you think about the commitments that are out there, is there any way to kind of break down what percentage of the commitments are driven by fundamental economics as opposed to a company that just philosophically believes it's better for the planet, so they're going to do it anyway?

Speaker C: That's a good question, Eric. We're several years into many of the net zero commitments that we've seen made by companies. Certainly in early days when net zero commitments were first announced, it would have been hard to identify data in support of what is the thought and substance and strategy. But over the last several years, through public reporting, through the proxy process for many public companies, much more information has come out which introduces to companies additional opportunity to uh, stand out as a leader or the risk of being viewed as somebody who has overstated commitments or probably the worst situation, uh, viewed as a laggard in this space.

Speaker A: Interesting. It's uh, good to see that the visibility is increasing there. Could you talk a bit about the influence of state governments? Given that some, like California, are in favor of ESG initiatives and others are resistant or simply against them at the

Speaker C: national level, we're experiencing this major policy shift away from a focus on climate mitigation, more toward what is best for America. And what we're seeing is states exercising the autonomy they have under the US Constitution in many areas. California is an example of a state that has increased its efforts in ESG initiatives, arguably in an accelerated way because of the swing of the political pendulum at the federal level. And state action has also resulted because of the inability of Congress to come together around anything bipartisan around climate climate change mitigation. Now, California has taken an approach not only to reduce emissions through its low carbon fuel standard program, but also to require climate related disclosure of companies that do business in the state of California. And that's a fairly low threshold, that doing business threshold. And so companies that don't view themselves as being domiciled in or headquartered in California still have requirements under the California climate disclosure rules to disclose publicly their greenhouse gas emissions, their year over year emissions, as well as how they approach climate governance. Conversely, there are several states, including my home state of Texas, that have taken measures to push against strong pro ESG opportunity through Efforts such as withholding state pension investments or even the ability to contract with the government for businesses that are viewed as boycotting oil and gas, or boycotting ammunition or gun companies, or even in the diversity, equity and inclusion space, the Attorney General of Texas and several other states have pursued actions against federal DEI initiatives. We see this autonomy of states and this federalism divide playing out in action before us.

Speaker B: This has played out many times before in different contexts where the federal regulation doesn't address something and then the states that want to come in, uh, and the result is a patchwork of regulation. And this has a, like, long history of just being notoriously difficult for clients to manage. And so we would expect, you know, that to play out here. Interesting too, this is a little bit of an academic point, but the logic of the states rights agenda of the administration, whether in sort of the approach to the Education Department or around abortion rights, is really to, you know, push regulation back and authority back over to the states. And so the implication is really to empower the states, red or blue, to fill the regulatory void.

Speaker A: And to be clear, to the extent that the federal government imposes regulation that is inconsistent with rules or regulations that might exist in, say, the state of Texas, at the end of the day, that state is going to have to comply with federal, uh, regulations such as they are. Is that a fair assessment?

Speaker C: In many ways, yes. That is a fair statement. Certainly the interstate commerce clause would come into play in the energy space if it was a federal rule associated with energy development. I think there are legal battles to be played out as to what issues are true, local issues.

Speaker B: Taylor, correct me if I'm wrong, but I think of the Feds as setting a floor, not a ceiling. So when it comes to emission regulations or, you know, water discharge regulations or any of the things that practically impact energy projects, there's always the possibility for states to go more stringent. It's just they choose not to if the federal level is reasonable. It's only when the feds are seen as not occupying the space that the states ramp up in their maybe more severe, you know, more stringent permitting. Is that fair?

Speaker C: That's a really good point.

Speaker A: So we've talked a bit about California. What about the influence of the, uh, European Union or other jurisdictions on energy transition, especially in light of the fact that, uh, some regulations have extraterritorial application?

Speaker C: Yeah, very good question. Look, many of the more aggressive and pro ESG regulations have come from Europe. The EU has taken significant steps in the way of ESG regulation through the eu Green deal through a number of different taxes or border, uh, transfer mechanisms. And I would just note two very significant directives, the Corporate Sustainability Reporting Directive, or csrd, and the Corporate Sustainability Due Diligence Directive, or csdd. Together, the CSRD and the CSDD really represent a paradigm shift when it comes to ESG regulation in that the due diligence obligations under the CSDD extend to businesses globally. As a company is required to do due diligence in its supply chain, this results in a cascading of data generated, a cascading of obligations to continue to do due diligence outside of Europe. And then when you layer on the reporting obligation of the csrd, it's not only that that data is available, but that data is included in public disclosure and thereby, uh, this transcends borders in the EU and will result in a substantial amount of transparency.

Speaker A: Let's turn to the uh, investor mindset. Do you expect investors to remain enthusiastic about sustainability and decarbonization?

Speaker B: I think there's an optimism in the industry that this administration wants to unlock investment and that there could also be some opportunity within the, uh, turmoil and uncertainty of these first hundred days. A couple of examples. So in supplying power to data centers and digital infra, that's a well advertised developed thesis. And maybe there are opportunities where the deregulatory agenda can actually sort of help accelerate that opportunity. On the sort of molecule side of the clean energy industry, I think there's some optimism that the traditional energy companies will get behind preserving the tax incentives that benefit carbon, capture that benefit hydrogen, and maybe even sort of steer the administration to loosen some of the stringent requirements that were imposed under the Biden's IRS guidance. Strategically, a lot of the federal investments, and here I'm mostly thinking under the IRA are in red states. So I think there remains optimism that Congress has enough Republican supporters for smart projects in their own districts that they won't, uh, unwind the fundamental tax credit policies that drive a lot of the investment into the space.

Speaker C: Let's be very clear, the government incentives, the tax credits, the direct pay opportunities under the Inflation Reduction act, as well as other government programs, these truly improve the economics of the energy transition technologies and projects that are underway. So I expect investors to continue to play ball. The other factor that I believe encourages ongoing business activity, again is the commitment made by companies around climate as well as around other ESG issues. There is tangible legal and reputational risk associated with walking back from a corporate commitment on these topics. And that legal risk can come in the form of shareholder derivative Suits, it could come in the form of a greenwashing or a blue washing claim, that is alleging that a company has overstated its environmental benefit or its commitment to social programs. And those types of lawsuits can show up in headlines and become much more noise than a company would prefer. And as a result, commitment to ESG focused statements as well as investments has enough of a tailwind ahead.

Speaker A: You know, we've heard from Trump about unleashing all types of energy in the US in part to bring down the price of energy, I think, for the consumer. And does that mean potentially that these energy transition avenues can actually perhaps increase during the Trump administration alongside maybe more traditional types of energy such as oil and gas?

Speaker B: I think the answer is yes. I think, uh, and this sort of gets to how this is actually going to play out. It's still early, we're still in the first hundred days. There's a sense that this is an opening salvo and there's a lot of disruption coming out of the administration to see what they can do. But I think a lot of the industry supporters, and there's a lot of industry showing up in government, is interested in an all of the above approach, in large part because of the economic benefit of driving down cost of energy and reducing some of the inflationary pressures. And so I think a lot of the attacks coming out, whether it's, uh, on federal wind permitting or on the outflow of government funds, I think let's take our time and sort of watch it play out. Because if you look at the logic and you look at it from an industry perspective and what investors want, there could be a lot of opportunity here for investment across a, uh, real all of the above approach. So I think there's a little bit of separating the sort of noise from signal in the beginning of what can be viewed as kind of a negotiation. And this is an opening position out of the administration.

Speaker A: So we've talked about the influence of government. What about the influence and impact that, uh, employees or shareholders might have on energy transition?

Speaker C: Employees as well as shareholders fit within this definition of a stakeholder. That's a more broad term than shareholder. Obviously, additional stakeholders would be suppliers, customers, local communities. And what we see in a sustainability focused discussion is meeting the interests and even a sense of moral obligation to a broader stakeholder group and not just shareholders. An example where this is reflected and communicated is the Business Roundtable issues a statement around the purpose of a corporation. And in 2019, that statement, which previously for 20 years had communicated that the primary purpose of a corporation was to deliver uh returns for its shareholders. Beginning in 2019, it moved away from that shareholder focused model to a broader stakeholder model where there are shared commitments to all stakeholders. So it's a broader discussion when it comes to how a company conducts its business and the purposes of their operations. Another dynamic is that younger generations appear more interested in investing in or supporting companies that align with the individual's values. And younger generations seem to prioritize some of these sustainability focused topics. Diversity, equity and inclusion climate. These are topics that are included in a broader stakeholder primacy focus of sustainability. And so consequently, companies feel not only an obligation to, but an opportunity to gain a positive reputation or even differentiate themselves from competitors by paying attention to that broader stakeholder group.

Speaker B: I think the reference to the Business Roundtable statement is kind of fascinating because when it came out, I don't think it got a whole lot of attention. And yet in hindsight people pointed back to it. And I think in some ways it was just reflecting the reality that as corporations and companies think about what it means to maximize their value for their shareholders, they realized, look, if we alienate our customers or our employees, then over the long term that's not going to be good for our shareholders either. And so I think it was sort of a revolutionary statement in a way, but it was also just a logical application of the idea of how do you maintain long term value for your shareholders? Well, you better make sure you don't alienate these populations of people on which you depend as a business.

Speaker A: We've touched on bits and pieces of this, but uh, just maybe to kind of bring it home for me, how do you see these trends that we've been talking about influencing investment, particularly around energy transition and sustainability sectors?

Speaker B: I would come back to just the inevitability of energy transition and increased focus on sustainability as a matter of societal preferences, um, as well as environmental need. I think investors invest in these areas because the deals make sense. Maybe early on, uh, or maybe around the edges around impact investing, people might take more concessionary returns, but these investments are all predicated on making money. And the reality is that a lot of these areas, whether it's low carbon energy or sustainability, theses are ripe for investment because there's an underserved area there. And as a result they make solid risk adjusted returns. And it's not just power and renewables, it's strategies like water and circular economy and environmental services and critical minerals. You know, I see it a little bit in historic context. If you go back to 2008 2010. In my mind, that's when investors were forced to analyze ESG risks in many cases for the first time, either because of climate change, focused SEC disclosure, or maybe under project finance principles at the time. Since then, the funds and the LPs have sort of embraced these same principles, not because they hamper their business in any way, but because using this lens of sustainability, you, uh, can more readily identify long term vulnerabilities and risk in an investment. And so as I sort of think about what's playing out in the sector, I think people may steer away from the terminology of ESG and sustainability, they probably will. But the need to critically assess things like social license to operate, supply chain vulnerability, natural resource dependency, climactic changes, these are all part of investment and they should be because each of these themes can pose a risk to whatever you're investing in. So I think that's a big part of how I see it sort of playing out and coming together from an investor standpoint.

Speaker A: So we've been talking a lot about Trump and he may set, uh, broad policy, but his picks for key cabinet posts and agency heads, you know, the real implementers, will have far reaching implications. Trump's choices to head several federal agencies already reflect a significant departure from the priorities of the Biden administration. How do you expect these appointments to affect your clients and which are likely to have the greatest impact?

Speaker C: Well, President Trump ran on a campaign of lowering regulatory burden. And so I think one of the more immediate impacts that we may see is new political appointees revisiting or reshaping enforcement priorities of agencies and reviewing policies that came out in the last few years. And two of the agencies that are very relevant to ESG are the U.S. environmental Protection Agency as well as the securities Exchange Commission. The appointee as EPA administrator is Lee Zeldin, not viewed as one who has focused on environmental protection throughout his career, but he does have a background in local government issues. And there are a number of EPA rules that came out in the last 18 months which industry has spoken up about as resulting in significant burden, even significant uncertainty because of the breadth of the regulatory, uh, compliance obligations that, uh, I would expect Zeldin to look at again. Paul Atkins was announced as SEC chair, and by all reports, he is likely going to take a very different approach to climate disclosure regulation than his predecessor, Gary Gensler. And so those rules that were finalized in early 2024 are likely to be revisited if not retracted. Those types of regulatory changes, policy changes, even changes to enforcement priorities, will have impact into how companies interact with agencies, as well as how companies are required to disclose to Sharehold and the public what they're doing in the space of climate change.

Speaker A: Let's talk a little bit about some of the laws and rules that have been put in place and, uh, those that you think are potentially more vulnerable to being revoked. I'm hearing that there's risk around the Inflation Reduction act, at least in part, the US Support of the Paris Agreement, which Taylor had mentioned earlier, and SEC climate disclosure rules. Can you tell us what makes a law or rule more vulnerable to change by the new administration?

Speaker C: What makes a law or a rule more vulnerable to amendment or retraction comes down to how the law or rule came into effect, as well as the status of that rule. There is a difference in vulnerability between legislation, regulation, and agency guidance. The most secure is going to be legislation, and the least secure is going to be agency guidance. And the reason for that is legislation has been through the congressional process. Both Houses have passed a rule, been signed into law by a president, and by the stroke of a pen, a president, uh, does not have effect to overcome that legislation. However, much legislation relies upon implementing regulations, and regulations are required to follow certain procedures to have that force of law. And those procedures are set out federally in the Administrative Procedures Act. So if a regulation follows the Administrative Procedures act and has been finalized, that regulation should be viewed as quite secure. There are a number of rules that might not yet have been finalized, and that really matters, because a rule that has not been finalized is something that can be revoked by an agency or through the stroke of a pen. The SEC's climate disclosure rules have been finalized. However, they're subject to a stay by the sec. They have not gone into effect. And so that status, to me suggests some uncertainty as to whether they will stay around because companies have not yet had to comply with the disclosure obligations of those rules. Because within days of being finalized, the SEC was subject to a number of, uh, legal challenges and elected to stay the effect of those rules until litigation ran its course. The Inflation Reduction act is going to be less vulnerable because it is an act of legislation. However, some of the enabling regulation of the Inflation Reduction act, which primarily relies upon US treasury, could be revisited. So the dollar amount, for example, of tax incentives or the number of tax incentives available which shows up in implementing regulation, um, may be revisited by this new administration. The most vulnerable is going to be agency guidance. Because agency guidance is not required to comply with the Administrative Procedures Act. It essentially is a policy statement and therefore can be changed practically at a whim of new agency leadership or by way of executive order.

Speaker A: Taylor, you've just taken me back to my, uh, administrative law class in law school, and that wasn't altogether a favorable memory.

Speaker C: We'll take that as a compliment, Eric. Thank you.

Speaker A: All right, Hayden, look, I'm a deal guy. Structuring and investing in deals requires a clear understanding of the rules of the game. How do you see investors navigating the uncertainty, uh, of the current environment?

Speaker B: It's a great question. It's sort of where the wheels meet the road. So from m an investor standpoint, project development has always been the hard part. That's why investors pay such a premium for de risked operational platforms, portfolios and projects. There's always been plenty of capital. The issue has always been how do you find the teams, the people that can develop and execute great projects on time and at least remotely close to budget? Most of the regulatory uncertainty that we're talking about here affects the ability to develop projects, navigate federal approvals, obtain permits, anticipate challenging areas, and build in lead time for them. So these changes that we're talking about tend to benefit strong development teams, strong platforms with good development chops. We also see it in how investments are actually being structured. I mean, if you go back to 2021, 2022, investors paid a premium for big development pipelines on the assumption that those projects would all get built. Investors don't do that anymore. A lot of them got burned. The development risk is always present. It might be higher, it might be lower, given the political climate. But from a deal perspective, investors really just need to focus on understanding what that risk is and then calibrate their incentives through deal structures and invest in a way where their investment dollars are aligned with successful outcomes.

Speaker A: Great, thanks. I'm hoping you guys can give me a bit of a history lesson now. A new administration is obviously a time of change, but change doesn't happen in a void. There are always historical drivers. We've just come off four years of the Biden administration. We also have Trump's first term as a guide. Can you put today's changes into, uh, an historical context for our listeners?

Speaker B: One of the trends I've been thinking a lot about is how the big utilities, power companies handled the increasing federal regulation over a long period of time. As we started to drive the shift from baseload coal to baseload natural gas in this country, there was a string of water and air regulations that were passed and then unwound and then reinstated by the next administration and then challenged in court. And so on over a decade or more. And I think at some level, industry eventually said the only thing worse than big lumpy capital expenditures is uncertainty. Having clear and unchanging regulation, even if burdensome, was better than confusion and uncertainty. And so, as I think about some of the appointments coming from an industry perspective, I'm optimistic that industry is going to be asking for certainty. They're going to be asking for the continuation of some of these incentives that are really beneficial to their bottom line. And I'm optimistic that the administration will see the wisdom of doing that as a way to drive investment dollars really across the for the betterment of the economy.

Speaker C: In my view, this administration change feels like one of the more aggressive swings from left to right in my lifetime. Hopefully this Trump administration will build on common ground. During the first Trump administration, we saw significant expansion of tax credits around carbon capture, Utilization and storage, and the Inflation Reduction act expanded the life of those credits. And I think in energy development in particular, because of this objective of putting America first and making energy resources available and economical, that regulation certainty can improve the opportunity. I like your point as well, Hayden, about industry members and their voices being more prominent in this administration that that has potential for less of a divide, at least between industry viewpoints and government viewpoints.

Speaker A: I'm trying to understand to what degree we might see Trump's first term as some sort of precedent. What happens during Trump's first term. When you think about a big picture,

Speaker B: there were a lot of blue states, even some cities who tried to serve as a counterweight to the first Trump administration. There was like the we're still in campaign after we withdrew from the climate accords. We saw it in the renewable offtake mandates out of Massachusetts and other states in New England. I don't see this being quite as significant a dynamic this time around. Uh, I think the states have already set ambitious RPS targets, uh, where they can. I don't see them having as much Runway left to take that strategy here. That said, I think that a lot of the projects we're talking about, the ones that have already been permitted or already begun to be funded, they are in states. And we'll see states that are hosting those projects, uh, do what they can, both from a permitting standpoint and just overall economic support for those projects, uh, getting done. And I think given what we're talking about here, about showing a sort of all above approach and getting projects done despite, despite the uncertainty and headwinds, m, maybe that's the best thing states can be doing in this environment.

Speaker A: Thanks, that's helpful. And as we come to the close here, just getting to some of the top takeaways. How would you characterize the changes that are occurring and expected to occur during this administration? Are they going to be transformative for business and your clients, or might we see a reversion to a more business as usual approach?

Speaker C: Look, we expected a sprint out of the gate by the new Trump administration. We absolutely have seen that. In similar ways, we saw the Biden administration take a number of aggressive executive actions within the first few weeks of his presidency. I expect things to slow down. Companies will continue to operate in a way where the lowering of uncertainty increases the willingness to apply capital. And so I think with the calming of change, hopefully we will see more of a, um, proactive effort by industry in new commitments in respect of allocation of capital in the energy space as well as other types of business.

Speaker B: I would agree with all that. As I think about how clients should approach this. There's a lot here to monitor and I would say be proactive, talk to colleagues, ask questions. There's a lot moving, there's a lot to monitor. And I think just recognize that, particularly when you're in a live deal, part of what Taylor set out before, in terms of what are the existing laws, what's guidance, what's regulation and what's statutory, I think it's very helpful to go back to that and have that framework for the basics. You know, what can be affected at an agency level and what requires an act of Congress. A lot of my focus is obviously on the ira. It's a big driver, uh, in the energy transition space. And I think it's worth remembering that it was kind of purpose built for this change. And sure there are definitely some pieces that are vulnerable and that could be scaled back, but really by design. The reason it was able to pass was because it was mostly carrots and very few sticks. It had something in it for everybody. And a lot of those carrots are in red states and are designed to help traditional energy companies really advance through the energy transition.

Speaker A: All right, a final quick take, 30 seconds or less. Taylor, big picture takeaway for clients.

Speaker C: The energy transition is going to continue. The future of the world is a lower carbon future. And although we're experiencing change from an administration that took an all of government approach to combating climate change, the Trump administration, uh, although it has pulled back, does facilitate continued interest of investors, continued interest of employees, uh, and other stakeholders to see sustainable, responsible business that supports an energy transition and a lower carbon future.

Speaker B: Hayden, I think going back to your question before about seeing the administration change, I guess one way to think about it is look at the common denominator. The pendulum moves from the left, the pendulum moves to the right in a federal administration. But look at what stays the same. Look at where investment dollars go. Look at what company commitments, a broader trajectory toward decarbonization over decades. And in some ways, these administrative changes are a opportunity to see what's down the fairway. And I would say there's an awful lot that is very clearly unchanging and that's where a lot of the investment theses and opportunities really are.

Speaker A: Taylor Hayden, thank you both for joining today. You've offered some valuable insights into the shifting ESG landscape and the new administration's role in reshaping energy transition in the US and globally. You're both right in the middle of it all. I will be watching in fascination from the sidelines in the months and years ahead.

Speaker B: Thanks, Eric.

Speaker C: Thanks, Eric.

Speaker A: Thanks for listening. Please subscribe in your preferred podcast app so you don't miss future episodes until next time.