New York State Supreme Court Mandates Enforcement of Greenhouse Gas Emissions Limits

In a landmark decision on October 24, 2025, the New York State Supreme Court in Albany County ruled that the Department of Environmental Conservation (DEC) must issue regulations to enforce greenhouse gas (GHG) emissions limits as mandated by the Climate Leadership and Community Protection Act (CLCPA) of 2019. The court found that the DEC failed to meet the January 1, 2024, deadline for promulgating these regulations and ordered the agency to comply by February 6, 2026.

The CLCPA, enacted in July 2019, sets ambitious targets for reducing GHG emissions—40% below 1990 levels by 2030 and 85% by 2050, with the ultimate goal of achieving net-zero emissions across all sectors of the economy by 2050. To facilitate these objectives, the Act established the Climate Action Council, a 22-member body tasked with developing a scoping plan to guide the state's transition to a clean energy economy. Additionally, the Act requires the DEC to promulgate regulations ensuring compliance with the statewide GHG emission limits by January 1, 2024.

The lawsuit was initiated by a coalition of environmental and community organizations, including Citizen Action of New York, People United for Sustainable Housing Buffalo (PUSH Buffalo), the Sierra Club, and WE ACT for Environmental Justice. These groups were represented by Earthjustice, New York Lawyers for the Public Interest, and the Pace Environmental Litigation Clinic. The plaintiffs argued that the DEC's failure to issue the required regulations constituted a violation of the CLCPA and hindered the state's progress toward its climate goals.

Justice Julian D. Schreibman emphasized that the DEC's failure to act was a violation of the law and that the agency must comply with the legislative mandate without further delay. The court's decision underscores the enforceability of legislative mandates and the limited discretion agencies have in implementing such policies.

This ruling has significant implications for companies operating in New York, as they will need to prepare for compliance with forthcoming regulations and participate in public comment periods. It also highlights the state's commitment to addressing climate change through enforceable regulatory measures.

The ruling reinforces the importance of governmental accountability in addressing climate change. It also emphasizes the role of environmental justice organizations in holding state agencies accountable for implementing laws designed to protect public health and the environment. The decision is seen as a victory for communities disproportionately affected by pollution and climate change, ensuring that the state adheres to its commitments to reduce emissions and promote environmental justice.

This case is part of a broader trend of legal actions aimed at compelling governmental agencies to fulfill their statutory obligations related to climate change. Similar lawsuits have been filed in other states, reflecting a growing movement to enforce climate legislation through judicial means. The ruling in New York sets a precedent for other jurisdictions where agencies have been slow to implement climate-related regulations.

The New York State Supreme Court's ruling serves as a critical reminder of the legal obligations state agencies have in implementing climate legislation. As the February 6, 2026, deadline approaches, both the DEC and businesses operating in New York must take proactive steps to ensure compliance with the forthcoming regulations, thereby contributing to the state's ambitious climate goals.