Energy Workforce recently submitted comments in response to three separate proposed regulations that if enacted, would have significant impacts on Member Companies. These proposed rules come from three different federal agencies and have the potential to affect the energy industry’s business operations, growth, existing projects and environmental standards. Below is a breakdown of each of these regulations and Energy Workforce’s response to these proposals.
EPA: Greenhouse Gas Reporting Rule: Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems
On August 1, 2023 EPA set forth a series of proposed amendments to the Petroleum and Natural Gas Systems source category, also known as subpart W, under the Greenhouse Gas Reporting Program (GHGRP). The proposed amendments encompass four key areas, including: Addressing Gaps in Emissions Reporting; Improved Emissions Calculation Methodologies; Enhanced Verification and Transparency; and Technical Amendments, Clarifications, and Corrections.
In its official comments Energy Workforce requested a 60-day extension of the comment period for this proposed rule. Citing the original 60-day comment period as an unrealistic timeframe for industry to review the extensive 600 pages of technical documents and impact analyses (with 175 additional documents in the docket), and provide thorough and accurate feedback in response to the rule. > READ COMMENTS
COUNCIL ON ENVIRONMENTAL QUALITY (CEQ): National Environmental Policy Act (NEPA) Implementing Regulations Revisions Phase 2
On July 31, 2023 CEQ released its Phase 2 proposed changes to NEPA regulations. These proposed changes included: the addition of environmental justice and climate change impacts that must be considered in a NEPA review; a revised definition of “major federal action;” a limit to EIS requirements and allowance of project sponsors to prepare EIS’s; and changes to the use of categorical exclusions.
Due to the size and scope of the proposal Energy Workforce requested a 45-day extension to the comment period. This would allow industry the time to review and comment on the extensive nature of the proposed requirements and their potential impacts on current and future business operations. > READ COMMENTS
U.S. FISH & WILDLIFE SERVICE (FWS): Dunes Sagebrush Lizard 12-Month Finding and Proposed Rule
On July 3, 2023 FWS announced a proposal to list the Dunes Sagebrush Lizard as an endangered species under the Endangered Species Act. This action would have a significant impact on Energy Workforce’s Members’ business planning and operations by increasing operational costs, delaying project timeframes, and limiting or precluding operations in certain areas.
Energy Workforce originally requested an extension of the comment period for the proposal, which was granted in response to this request. In the final comments Energy Workforce argued FWS does not supply adequate data to support the listing of the DSL as an endangered species. Additionally, Energy Workforce highlighted the conservation agreements between regulators and industry, and noted the success of these efforts in protecting the habitat of the DSL. > READ COMMENTS
The Energy Workforce Government Affairs team will continue to monitor these proposed regulations and all regulatory actions that may impact Member Company operations. If you are interested in Energy Workforce’s advocacy efforts or would like to join the Government Affairs Committee, contact Senior Director Government Affairs Deidre Kohlrus.
Deidre Almstead Kohlrus, Senior Director Government Affairs, writes about industry-specific policies for the Energy Workforce & Technology Council. Click here to subscribe to the Energy Workforce newsletter, which highlights sector-specific issues, best practices, activities and more.