Apr 10, 2023 Natural Gas Council Comments Re: National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, Council on Environmental Quality, CEQ-2022-0005
Dear Chair Mallory:
The Natural Gas Council, on behalf of the people and companies who produce, transport, and deliver U.S. natural gas across this country and around the world, urges you to withdraw the National Environmental Policy Act (“NEPA”) Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, 88 Fed. Reg. 1,196 (Jan. 9, 2023) (“Guidance”).
The Guidance inappropriately transforms NEPA into a tool that promotes use of certain types of energy and obstructs use of other types. The Guidance establishes a “two track” approach to NEPA review that (1) deters development of natural gas production and infrastructure by adding unduly burdensome requirements to the NEPA review of natural gas projects and (2) expedites review of wind and solar projects by exempting those projects from the requirements imposed on natural gas production and infrastructure. This disparate treatment is not grounded in law or fact, but instead appears to reflect a mistaken belief that natural gas inexorably impedes efforts to address climate change and that the federal government must discourage natural gas production and infrastructure development to successfully address climate change.
Natural gas is not an obstacle to the clean energy transition; it is an essential component of that transition. Since 2005, carbon dioxide emissions in the electric power sector have declined by about 35 percent, with a switch from coal to natural gas accounting for about two-thirds of the decline. …
