The Biden OIRA will have a hand in this matter even though the transaction is being undertaken by an “independent” agency. Under the Paperwork Reduction Act (PRA), recordkeeping and reporting requirements must be approved by OIRA.
Given the priority that the Biden Administration accords to Climate Change it might be too early to predict the outcome of this matter. It should be noted that both the SEC and OIRA are bound by the standards in the Information Quality Act when they act on PRA transactions.