American Oil and Gas Reporter - August 2023 - 106

prompts doubts about its legal durability.
" Vastly overestimating baseline emissions
reductions, materially underestimating
future electricity demand, and
forcing a specific technology for which
EPA's own projections and real-world
data do not support widespread adoption
completely changes the projected impact
of the rule on the economy and the ability
to maintain the reliability of the nation's
electricity grid, " the report concludes.
" These issues also make the rule vulnerable
to legal challenges. The climate challenge
requires transparency from both government
and industry and for all stakeholders
to work together in good faith. EPA
should work collaboratively with stakeholders
to address these shortcomings
and develop more realistic modeling scenarios
that better reflect the effectiveness
and impacts of its rule. "
❒
Groups Urge EPA To Nix Tailpipe Rule
WASHINGTON-A coalition of
more than 100 trade groups representing
diverse businesses, including numerous
oil and gas associations, are urging the
Biden administration to reverse course
on its proposed tailpipe emissions standards
for light-, medium- and heavyduty
vehicles. In a letter to President
Biden, the organizations have outlined
significant concerns with EPA's proposed
rules and the need to preserve consumers'
access to affordable, reliable
and efficient transportation.
The letter's signatories include the
Arkansas Independent Producers & Royalty
Owners Association, Colorado Oil
& Gas Association, Louisiana Oil & Gas
Association, Ohio Oil & Gas Association,
Pennsylvania Independent Oil & Gas Association,
Western Energy Alliance and
American Petroleum Institute.
" We share the goal of reduced greenhouse
gas emissions across the broader
economy and, specifically, those from
energy production, transportation and use
by society, " the letter states. " EPA's proposals
inhibit the marketplace from identifying
the most efficient, lowest cost opportunities
to reduce GHG emissions
from vehicles and greatly restrict consumer
choice. We are concerned that such a
prescriptive policy is not in the best
interest of the consumer or of U.S. energy
and economic security. "
The letter raises further concerns with
EPA's narrow focus on electric vehicles
to achieve compliance and highlights the
benefits of evaluating a broader range of
emissions reductions pathways.
" A diversified portfolio of vehicle and
fuel technologies that meets the multitude
of transportation needs of Americans and
makes meaningful GHG reductions can
be achieved while also allowing new
zero-emission vehicle (ZEV), and specifically
battery electric vehicle (BEV), technologies
to advance, " the coalition maintains.
" Improved crop yield, innovative
biofuel and refined product processing,
and manufacturing efficiency tied with
carbon capture each represent promising
advancements for current liquid and
gaseous fuels to continue to accelerate
emissions reductions. "
Along with oil and gas producer groups,
the signers include state and national
agricultural groups, including corn growers,
farm bureaus, and ethanol producers;
petroleum marketers and fuel dealers;
convenience store and truck stop operators;
refiners; and motor truck associations.
Economic, Geopolitical Risks
The coalition warns that EPA's proposals
not only will distort the marketplace
in a way that may prevent it from identifying
the most efficient, lowest cost opportunities
to cut vehicles' GHG emissions,
it also will undermine consumer choice
significantly.
" We are concerned that such a prescriptive
policy is not in the best interest
of the consumer or of U.S. energy and
economic security, " the letter relates. " According
to the EPA, fuel and vehicle technologies
have reduced emissions from
common pollutants by roughly 99% in
both light- and heavy-duty vehicles and
buses, and carbon dioxide emissions from
light-duty internal combustion engine vehicles
(ICEV) have decreased 25% since
model year 2004.
" According to the U.S. Energy Information
Administration, there are about
272 million ICEVs on the road today,
and EIA projects over 140 million ICEV
sales will occur between 2023 and 2032, "
the coalition continues. " Further, EIA
projects there will be about 269 million
ICEVs in the fleet in 2050 along with 47
million battery electric and plug-in hybrid
electric vehicles. As such, energy and
carbon reduction policies should consider
opportunities to address emissions from
the existing fleet. "
Therefore, the letter urges, EPA should
weigh a broader range of options for reducing
GHG emissions from light- and
medium-duty vehicles, such as renewable
liquid fuels and opportunities for market-based
solutions. It calls for a diversified
portfolio of vehicle and fuel technologies
that can meet Americans' multifaceted
transportation needs while achieving
meaningful GHG reductions and also enabling
advancements in new ZEV and
BEV technologies.
106 THE AMERICAN OIL & GAS REPORTER
" The heavy-duty proposed regulation
is nontraditional in terms of reducing
GHG emission stringencies through driving
the penetration of ZEVs into the marketplace, "
the letter maintains. " EPA's approach
does not consider that GHG emission
reductions can also be achieved by
accelerating the turnover of existing fleets
to advanced diesel technology and using
more renewable and alternative fuels.
" These approaches could deliver substantially
more GHG emission reductions
sooner and at significantly lower cost than
the proposed rule, " it adds. " They can also
help to reduce emissions from city buses,
tractor-trailers, delivery trucks and other
vehicles critical to our economy while
heavy-duty ZEV infrastructure and vehicles
envisioned by the proposal are being developed,
tested and eventually deployed. "
Moreover, the letter observes, the administration's
proposal also risks exposing
U.S. energy markets to geopolitical risks.
" Pursuing a broader range of emissionsreducing
transportation pathways can also
help guard against an over-reliance on foreign
adversaries and volatile global supply
chains associated with critical minerals
that are necessary for rapid expansion of
electric vehicle markets, " it states.
" Our organizations have worked with
EPA on numerous regulatory programs
to successfully reduce emissions across
the transportation sector, " the letter concludes.
" We urge your administration to
reconsider these proposals from EPA to
better allow for emissions reductions from
a myriad of vehicle and fuels technologies
and strategies to be realized while meeting
Americans' transportation needs. We stand
ready to work with your administration
to improve these rules. "
❒
Coming In September
The Texas Alliance of Energy
Producers will hold its 2023 annual
meeting, Oct. 4 at the Hotel Drover
in Fort Worth. See the Official
Convention Section in the
September issue of The American
Oil & Gas Reporter.
American Oil and Gas Reporter - August 2023

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