American Oil and Gas Reporter - February 2023 - 83

evaluation of economically significant
regulatory actions to reduce GHGs that
include the full monetization of costs
and benefits as a part of regulatory
impact analysis. "
Moreover, he suggests, applying SCGHGs
to individual projects' NEPA reviews
will further confuse the public and
decision-makers by obscuring those projects'
estimated societal benefits, such as
energy supply, economic development
and national security.
On the matter of cost-effectiveness,
Padilla notes that CEQ's guidance urges
agencies to mitigate GHG emissions as
much as possible. " This creates an expectation
for agencies to maximize GHG
emissions reductions with no consideration
of the costs of doing so or of the
benefits that the project would provide, "
he observes. " API supports mitigating
the direct GHG emissions of projects,
and our industry as a whole and individual
companies with projects subject to NEPA
have a long track record of mitigating
GHGs to a sufficient level so as to receive
agency authorization. But the limitless
high bar to 'mitigate GHG emissions to
the greatest extent possible' is one that
agencies and project developers might
never clear, compromising our nation's
ability to build the energy projects that
we and our allies need. "
The Wrong Direction
Padilla's letter observes that NEPA's
shadow has grown dramatically since
the law's enactment, which has lengthened
reviews, sown confusion among
project sponsors and regulators, and
yielded divergent court decisions about
the review process.
" Costly delays within the complex review
process restrict project development, "
he writes. " Under the current NEPA
process, the average EIS takes four and
half years to complete, and 25% of completed
impact statements took more than
six years. Ten major infrastructure projects,
reflecting $34 billion in capital expenditures,
were cancelled, stalled or were at
risk of cancellation due to permitting and
review delays in recent years.
" This includes four natural gas projects
in Appalachia that could support 4.6
billion cubic feet per day of production
needed by families and businesses in the
region, " he adds. " In addition to delays,
the intense review process also creates
uncertainty, suppressing investment in
key infrastructure projects and hampering
U.S. oil and natural gas production. "
Padilla predicts CEQ's guidance almost
certainly will lengthen delays for projects
including oil and gas production on federal
lands and federal waters; interstate natural
gas pipelines; pipelines that cross federal
lands; LNG terminals; carbon capture,
utilization and storage facilities; and hydrogen
facilities.
" Delays in permitting these muchneeded
projects would compromise the
supply of affordable, reliable energy that
U.S. and global consumers use every
day, " he cautions. " They would compromise
the deployment of lower carbon solutions,
including CCUS and hydrogen
produced from both natural gas and from
electrolysis using electricity. And NEPA
permitting delays would compromise U.S.
and European energy security at a time
when Russia's invasion of Ukraine has
made U.S. oil and natural gas essential
to meet the needs of our European NATO
allies, Japan, South Korea and Taiwan.
" A robust natural gas industry enables
the United States to export our LNG
overseas, " Padilla continues. " The United
States is now the world's leading exporter
of LNG, reducing our allies' reliance on
countries with less-stringent environmental
regulations in supplying oil and natural
gas resources. The use of our LNG supports
emissions reductions worldwide,
supporting GHG emissions reductions
needed to meet international climate
goals. In order to ensure that U.S. oil and
natural gas resources can meet growing
demand and support the United States in
reaching its climate goals, the United
States must provide regularity and certainty
in the review and permitting of oil and
natural gas projects. "
Padilla closes the letter by emphasizing
his group's commitment to a better, more
efficient permitting process, and declares
CEQ's guidance contradicts that goal.
" Fixing the NEPA permitting process is
a priority for API: to establish agency
uniformity in reviews, limit review timelines
and reduce the burdens placed on
project proponents, " he concludes. " This
unsound CEQ Guidance is further evidence
that the NEPA process remains unnecessarily
complex, unreasonably time-consuming
and significantly uncertain, which
in turn impedes investment in the nation's
energy resources and infrastructure. " ❒
COMING SOON
MARCH
SPECIAL REPORTS
Gas Production & Processing
ESG Best Practices
Eagle Ford Playmakers
THE 2023 SERIES
Resource Plays - Part 3:
Frac Pumps, Engines and Emissions
Advertising Files Due: February 23
OFFICIAL CONVENTION NEWS
KIOGA - Kansas
TIPRO - Texas
PIOGA - Pennsylvania
OTHER SCHEDULED EVENT DISTRIBUTION
GCA Expo And Conference
AADE Technical Conference & Exhibition
Oilfield Chemicals Series North America
APRIL
Advertising Files Due: March 17
SPECIAL REPORTS
Drilling Tools, Bits and BHAs
Optimizing Laterals
Haynesville Playmakers
THE 2023 SERIES
The Innovators - Part 1:
Banks & Private Equity
OFFICIAL CONVENTION NEWS
TOGA - Tennessee
IPANM - New Mexico
OTHER SCHEDULED EVENT DISTRIBUTION
Offshore Technology Conference (OTC)
Multiphase Pump User Roundtable
Southwestern Petroleum Short Course (SWPSC)
FEBRUARY 2023 83
American Oil and Gas Reporter - February 2023

Table of Contents for the Digital Edition of American Oil and Gas Reporter - February 2023
