We live in a democracy, public comments are open for two draconian changes, by the SEC and FERC, intended to doom America’s oil & gas industry and infrastructure. Both are now open for your public comments. Commenting is easy, and its vitally important that you express your opinion. You can easily comment on government websites, or mail a traditional letter. Be firm and forceful, not emotional or pejorative. Identify yourself as a private citizen, not a lobbyist or O&G employee. If you don’t comment, realize that hordes of environmental zealots will dominate the input.
SEC Climate Related Disclosures. SEC proposed that every publicly traded company must disclose its contribution to greenhouse gas (GHG), not only its own emissions, but “Scope 3” emissions by its customers. The disclosures will be costly, burdensome, and foster endless litigation by environmentalists and activists.
Examples: Banks report how their lending and banking services facilitate GHG emissions globally. Exxon would report its own emissions, its refineries, tankers transporting oil and LNG, and emissions by a 2-3 billion consumers of Exxon products world wide. SEC admits the Scope 3 emissions are not defined. Even service companies not engaged in manufacturing would recite climate change prose or virtue-signaling, e.g. Neflix would disclose how its streaming service relates to greenhouse emissions.
SEC comments are quick and easy. Go to the website, click either webform or e-mail. SEC.gov | Public Input Welcomed on Climate Change Disclosures I gave SEC reasons this proposal is awful: SEC’s mandate is protecting consumers and fair markets (not the environment), SEC lacks environmental expertise, the rule is costly and disadvantages American companies, 10K annual reports are already unreadable and this makes them more unreadable, Russia & China would never impose onerous rules on their own companies, environmental matters are not SEC’s mission.
FERC – Consideration of Greenhouse Gas Emissions in Natural Gas Infrastructure Project Reviews FERC plans to reject permit applications by interstate pipelines and LNG plants by adding a new third test. FERC will evaluate greenhouse gas (GHG) emissions indirectly attributed to a project, the “downstream emissions” by ultimate consumers of gas, also known as Scope 3 emissions. Senator Joe Manchin castigated FERC in a hearing, so FERC claimed its February 2022 policy change was merely a draft, and now seeks public comment, public comment period ends 4/25/22. FERC already rejects and endlessly nitpicks pipeline and LNG terminal applications citing “environmental impact” pursuant to (NEPA) National Environmental Protection Act, and FERC encourages environmentalist lawsuits against oil & gas infrastructure.
FERC website is http://www.Ferc.gov You must cite Docket number PL21-3-000. I had trouble entering comments online to FERC, so I mailed an old fashioned letter to Federal Energy Regulatory Commission, Secretary of the Commission, 888 First Street NE, Washington, DC 20426.