Consistently ranked Band 1 in Energy Transition by Chambers USA (2025), Baker Botts offers a comprehensive legal platform for companies developing, financing, commercializing and operating renewable and low-carbon fuels businesses.

Our clean fuels practice supports market participants working with sustainable aviation fuel (SAF), renewable natural gas (RNG), biogas, ethanol, renewable diesel, biodiesel and other low-carbon transportation fuels. We advise developers, producers, investors, lenders, refiners, airlines, traders, feedstock suppliers, technology providers and other stakeholders on the legal issues that determine project viability, credit eligibility, financing structures, commercial risk allocation and long-term compliance.

Baker Botts brings firsthand agency experience with the regulatory programs that drive renewable and low-carbon fuels markets. Our team includes former U.S. Environmental Protection Agency (EPA) attorneys who implemented and enforced the federal Renewable Fuel Standard (RFS), as well as former California Air Resources Board (CARB) attorneys with experience in California’s Low Carbon Fuel Standard (LCFS). This experience gives clients practical insight into how these programs are developed, administered, interpreted and enforced.

Renewable and low-carbon fuels projects sit at the intersection of energy infrastructure, environmental regulation, tax incentives, commodity markets and evolving federal and state policy. Baker Botts helps clients navigate that complexity with an integrated team spanning project development, project finance, regulatory, environmental and compliance, tax, litigation and intellectual property.

We understand that value in the clean fuels sector depends on more than producing fuel. It depends on how projects are structured, how feedstocks are sourced, how carbon intensity is measured, how credits and environmental attributes are generated and monetized, how offtake agreements allocate risk, how tax incentives are preserved and how projects remain compliant as policy evolves.

Whether clients are launching a new facility, financing a portfolio, negotiating feedstock or offtake agreements, monetizing environmental/tax credits, acquiring clean fuels assets, responding to regulatory scrutiny or resolving a dispute, Baker Botts provides integrated counsel across the renewable and low-carbon fuels value chain.

What Renewable and Low-Carbon Fuels Challenges Does Baker Botts Solve?

Our multidisciplinary clean fuels team advises clients across the full lifecycle of renewable and low-carbon fuels projects and transactions. Our work includes advice and counsel related to:

• Federal and state clean fuels programs, including the Renewable Fuel Standard (RFS), Renewable Identification Number (RIN) generation and retirement, fuel pathway approvals, compliance strategy, audits, enforcement defense, California’s Low Carbon Fuel Standard (LCFS) and other state low-carbon fuel programs.
• Environmental credits and attributes, including federal and state environmental credits, LCFS credits, RINs, renewable energy certificates, carbon offsets, book-and-claim structures, voluntary and compliance-market credits, environmental attribute ownership and credit monetization.
• Tax incentives and credit monetization, including federal and state tax incentives, clean fuel production credits, tax-credit transferability, credit diligence, credit purchase agreements, tax-credit insurance, prevailing wage and apprenticeship considerations and integration of tax incentives into project finance and commercial agreements.
• Project development and finance, including project structuring, site control, permitting, construction arrangements, lender diligence, equity investments, project financing, tax-credit bridge financing, engineering, procurement and construction (EPC) contracts, operations and maintenance (O&M) contracts and risk allocation across the development and operating lifecycle.
• Feedstock, offtake and commercial agreements, including feedstock supply, offtake agreements, fuel supply contracts, tolling arrangements, sales and purchase agreements, transportation, storage, terminaling, blending, logistics, product specifications, environmental attribute allocation and change-in-law protections.
• Sustainable aviation fuel (SAF), including SAF project development, airline and corporate offtake agreements, fuel logistics, environmental attributes, emissions claims, book-and-claim considerations, tax incentives and regulatory compliance.
• Renewable natural gas (RNG) and biogas, including landfill gas, dairy, agricultural waste, wastewater and other waste-to-fuel projects; gas rights; interconnection; pipeline access; feedstock agreements; environmental attributes; credit monetization; and related project disputes.
• Renewable diesel, biodiesel and ethanol, including project development, feedstock procurement, fuel sales, blending arrangements, compliance with federal and state fuels programs, credit generation, tax incentives, logistics and commercial disputes.
• Environmental permitting and operational compliance, including air, water, waste, wastewater discharge, water rights, wetlands, environmental justice considerations, incident response and ongoing facility compliance.
• M&A, joint ventures and strategic investments, including acquisitions and divestitures of clean fuels assets, platform investments, renewable fuels joint ventures, private equity investments, diligence of regulatory credits and environmental attributes, and post-closing integration.
• Government advocacy, rulemaking and disputes, including agency advocacy, comments on proposed regulations, administrative proceedings, rulemaking challenges, enforcement defense, contract disputes, construction disputes, credit-related disputes and appellate litigation.
• Technology and intellectual property, including protection, licensing and commercialization of clean fuels technologies, processing technologies, catalysts, proprietary systems and other technology assets.
• Sustainability disclosures and reporting, including mandatory and voluntary climate-related reporting, emissions claims, environmental attribute substantiation and risk management related to public statements, customer commitments and stakeholder communications.