Wednesday, August 24, 2011
Friday, August 19, 2011
- The studies sponsored by industry groups (EEI and NERC) were written before EPA proposed most of the rules whose impacts they analyze, and they assumed that the rules would impose more stringent requirements than EPA proposed in many cases.
- Of the regulations so far proposed, the Utility MACT, which will set standards for power plant emissions of mercury and other hazardous air pollutants, appears to be the most expensive. EPA's analysis concluded that it will impose annual costs of $10 billion to $11 billion annually
- Other rules that industry expected to impose major costs now appear less likely to do so. The Cooling Water Intake rule, for example, proposes a less costly, more flexible regulatory option than EEI and NERC anticipated. Further, NERC believes that few coal-fired EGUs will be affected by this rule, which will have greater impact on older, oil-fired units. The Coal Combustion Waste Rule has been delayed, with no deadline for promulgation.
- For coal-fired plants, the primary impacts will be on units more than 40 years old that have not, until now, installed state-of-the art pollution controls. Many of these plants are inefficient, and are being replaced by more efficient combined cycle natural gas plants.
- Lower prices for natural gas and recent increases in its projected availability may reduce the impact of the proposed rules on electric utilities and consumers, although they may lead to more retirements of coal-fired units.
- There is a substantial amount of excess generation capacity at present, due in part to the recession and also due to the large number of natural gas combined cycle plants constructed in the last decade, muting reliability concerns.
Thursday, August 18, 2011
Wednesday, August 17, 2011
The CFS analysis was undertaken by the NESCAUM at the request of the Northeast states in 2009. The analysis assumed different scenarios accounting for uncertainties with gasoline and diesel demand, greenhouse gas emissions, fuel expenditures, delivery infrastructure and vehicle mix and macroeconomic factors such as employment and disposable income. Though the specifics of a regional CFS are still under development by the states, it would generally require fuel providers to gradually decrease the carbon intensity of their fuel, either by adding cleaner fuels into their fuel mix, or by purchasing credits generated by alternative fuels such as electricity or natural gas. The transition would reduce regional dependence on imported oil by diversifying transportation fuels to include domestic alternatives such as advanced biofuels, electricity and natural gas.
The NESCAUM report findings, which will be formally released soon, show that a CFS would:
- reduce oil consumption in the 11 states by up to 29 percent, or 9 billion gallons annually, in 2022 when the program is fully implemented
- increase total jobs by up to 50,000 over the 10-year period. The new jobs would be in various industries, including utility-related jobs due to increased demand for electricity and natural gas for transportation purposes, as well as manufacturing and construction jobs related to installing fueling infrastructure and building and operating biofuel and biogas production plants.
- increase cumulative net savings on transportation costs for households and businesses by up to $74.7 billion by 2022.
- Additionally, construction, manufacturing, forestry and agricultural services sectors would benefit. The health care and finance/insurance sectors would also experience positive indirect impacts.
Lubber, who leads a national coalition of investors and public interest groups working to build a sustainable economy, said of the findings, "NESCAUM's analysis demonstrates that a Clean Fuels Standard would bring significant economic benefits to the region and foster investment in a strong regional clean fuels system. The standard would provide the market certainty that investors and businesses need to invest in the development and production of alternative fuels, creating a robust clean fuels market and minimizing our vulnerability to volatile oil prices. By investing at home, rather than spending billions on foreign oil, the standard will also help create badly needed jobs."
Matthew Fitzmaurice, Managing Partner of AWJ Capital Partners, LLC, a global fund of funds manager, and member of Ceres' Investor Network on Climate Risk (INCR) added, "America's overdependence on oil generally, and foreign oil specifically, is unacceptable, as it will weaken our competiveness in a global economy. To change the status quo, we need clear standards. Investment capital now plays on a global stage, and capital represented by hedge funds will find its way into those economies and thus companies where clear standards exist. Failure to enact clean fuel standards will result in the U.S. becoming less competitive in the allocation of global investment capital."
Access a release from Ceres (click here). Access the Maine release of the 146-page NESCAUM "Economic Analysis of a Program to Promote Clean Transportation Fuels in the Northeast/Mid-Atlantic Region" (click here). Access the NESCAUM website for more information (click here). [#Energy/CFS, #Transport/CFS]
Tuesday, August 16, 2011
Advocacy states in the August 4, letter, "Today, EPA convened a Small Business Advocacy Review (SBAR) panel on its upcoming rulemaking, 'Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards (NSPS).' The Office of Advocacy (Advocacy) does not agree that this panel should have convened at this time. We believe that EPA is not yet ready for this panel, since it has not provided the other panel members with information on the potential impacts of this rule and will not provide small entity representatives (SERs) with sufficient information upon which to discuss alternatives and provide recommendations to EPA. It is Advocacy's position that EPA is not in compliance with the Small Business Regulatory Enforcement Fairness Act of 1996 (SBREFA) due to the lack of information provided and that a panel conducted under these circumstances is unlikely to succeed at identifying reasonable regulatory alternatives, as required by the Regulatory Flexibility Act (RFA). Advocacy acknowledges that EPA is conducting this rulemaking under court-agreed deadlines as part of negotiated settlement agreements, deadlines to which Advocacy objected in a public comment letter to EPA on January 19, 2011. EPA cannot rely on these deadlines to justify an inadequate SBAR panel." [Note: EPA indicates that it must comply with the settlement agreement proposal date of December 10, 2011 and promulgation date of November 10, 2012].
Monday, August 15, 2011
- Based on the preponderance of available data, the Council suggests an affirmative statement that BC appears to warm climate and that BC mitigation will produce both health and climate benefits.
Friday, August 12, 2011
"At a time when Americans are rightly focused on our economy, when Americans are asking about what's our path forward, all of you here at Johnson Controls are providing a powerful answer. This is one of the most advanced factories in the world. You're helping America lead in a growing new industry. You're showing us how we can come back from the worst recession that we've had in generations and start making things here in America that are sold all around the world. . . And that's why even in these difficult times, there is not a single country on Earth that wouldn't trade places with us. Not one. We've got to remember that. . .
"Unfortunately, what we've seen in Washington the last few months has been the worst kind of partisanship, the worst kind of gridlock - and that gridlock has undermined public confidence and impeded our efforts to take the steps we need for our economy. It's made things worse instead of better. So what I want to say to you, Johnson Controls, is: There is nothing wrong with our country. There is something wrong with our politics. There's something wrong with our politics that we need to fix. . .
"We know there are things we can do right now that will help accelerate growth and job creation - that will support the work going on here at Johnson Controls, here in Michigan, and all across America. We can do some things right now that will make a difference. We know there are things we have to do to erase a legacy of debt that hangs over the economy. But time and again, we've seen partisan brinksmanship get in the way - as if winning the next election is more important than fulfilling our responsibilities to you and to our country. This downgrade you've been reading about could have been entirely avoided if there had been a willingness to compromise in Congress. See, it didn't happen because we don't have the capacity to pay our bills - it happened because Washington doesn't have the capacity to come together and get things done. It was a self-inflicted wound. . .
"There are things we can do right now that will put more money in your pockets; will help businesses sell more products around the world; will put people to work in Michigan and across the country. And to get these things done, we do need Congress. They're common-sense ideas that have been supported in the past by Democrats and Republicans, things that are supported by Carl Levin. The only thing keeping us back is our politics. The only thing preventing these bills from being passed is the refusal of some folks in Congress to put the country ahead of party. There are some in Congress right now who would rather see their opponents lose than see America win.
"And that has to stop. It's got to stop. We're supposed to all be on the same team, especially when we're going through tough times. We can't afford to play games -- not right now, not when the stakes are so high for our economy. And if you agree with me - it doesn't matter if you're a Democrat or a Republican or an independent -- you've got to let Congress know. You've got to tell them you've had enough of the theatrics. You've had enough of the politics. Stop sending out press releases. Start passing some bills that we all know will help our economy right now. That's what they need to do -- they've got to hear from you. . ."
The President continued saying, ". . .over the coming weeks, I'm going to be putting out more proposals, week by week, that will help businesses hire and put people back to work. And I'm going to keep at it until every single American who wants a job can find one. Now, we do have to pay for these things. And in order to pay for these things, Congress has to finish the job of reducing the nation's budget deficit in a sensible, responsible way. Not just with more cuts this year or next year -- those cuts would weaken the economy more than it already is, and we've already cut a trillion dollars in what's called discretionary spending. What we need is a long-term plan to get our nation's finances in order. That's the only way we can invest in places like this. . . We can't ask the people in this room -- working families, middle-class families -- to bear the entire burden. We're not going to balance our budgets on the back of middle-class and working people in this country. Everybody has got to do their part. . ."
House Speaker John Boehner (R-OH) issued a statement on the President's remarks in Michigan and said, "American families and small businesses are hurting in this economy, and they are still asking 'Where are the jobs?' That's why Republicans have acted on common-sense, pro-growth policies aimed at creating a better environment for job creation. Republicans passed a budget that includes pro-growth tax reforms that will create jobs, real entitlement reforms, and more than $6 trillion in spending cuts. Republicans have introduced and are implementing a Plan for America's Job Creators. And the House-passed Cut, Cap & Balance Act is still sitting over in the Senate, where it could be taken up and passed immediately. President Obama likes to talk about being 'the adult in the room' -- but there's nothing 'adult' about political grandstanding. If the President wants to do something productive, he can start by delivering on his promise to outline his own recommendations to rein in the massive deficits and debt that are undermining job creation in our country."
Thursday, August 11, 2011
The report calls for industry leadership in improving environmental performance, underpinned by strong regulations and rigorous enforcement, evolving to meet the identified challenges. The Shale Gas Production Subcommittee Chairman John Deutch, an MIT professor said, "As shale gas grows and becomes an increasingly important part of our nation's energy supply, it is crucial to bring a better understanding of the environmental impacts -- both current and potential -- and ensure that they are properly addressed. The current output of shale gas and its potential for future growth emphasize the need to assure that this supply is produced in an environmentally sound fashion, and in a way that meets the needs of public trust. Better data will help the industry focus its investments, give the public the information it needs to effectively engage, and help regulators identify and address the most important problems," Deutch continued. "We're issuing a call for industry action, but we are not leaving it to industry alone."
On August 15, 2011, the full Secretary of Energy Advisory Board (SEAB) will convene a public meeting via conference call to discuss the draft report. Members of the public may submit comments on the draft report at any time, but comments must be submitted by noon on August 15, 2011, in order to be considered at this stage. Comments received after August 15, will be considered before the Subcommittee's final report is issued, which is scheduled for November 18, 2011. The Natural Gas Subcommittee met for the first time on May 18, 2011. Subsequently, it conducted public meetings on June 1-2, June 13, June 28, and July 13, to gather information and discuss issues surrounding hydraulic fracturing. As of July 15, 2011, DOE had received over 25,000 public comments.
The Subcommittee was tasked with producing a report on the immediate steps that can be taken to improve the safety and environmental performance of shale gas development. The report reflects three months of deliberations among a diverse group of industry experts, environmental advocates, academics and former state regulators. The report includes recommendations in four key areas:
1. Making information about shale gas production operations more accessible to the public
The report calls for the full disclosure of all chemicals used in fracturing fluids. While the committee agrees with the prevailing view that the risk of leakage of fracturing fluids through fractures made in deep shale reserves is remote where there are is large separation from drinking water, the report finds that there is no economic or technical reason to prevent public disclosure of all chemicals used in fracturing fluids. It also calls for the creation of a national database of all public information made about shale gas. Assembling the data, which are currently dispersed in perhaps a hundred different locations, in a comparable format would permit easier access by all interested parties. The report recommends government funding support for existing, multi-stakeholder mechanisms such as the non-profit Ground Water Protection Council's Risk Based Data Management System and the State Review of Oil and Natural Gas Environmental Regulation.
2. Immediate and longer-term actions to reduce environmental and safety risks of shale gas operations, with a particular focus on protecting air and water quality
Air Quality: The report says that measures should be taken to reduce emissions on air pollutants, ozone precursors and methane as quickly as practicable and supports prompt adoption of standards to reduce emissions of all air contaminants. The subcommittee recommends the design and rapid implementation of measurement systems to collect comprehensive methane and other air emissions data from shale gas operations. The subcommittee also recommends that a federal interagency planning effort be launched immediately to acquire data and analyze the overall greenhouse gas footprint of shale gas operations throughout the lifecycle of natural gas use in comparison to other fuels.
Water Quality: The report urges the adoption of a systemic approach to water management based on consistent measurement and public disclosure. Companies should measure and publicly report the composition of water stocks and flow throughout the process; manifest all transfers of water among different locations; and makes recommendations about best practices in well development and construction, especially casing and cementing. Likewise, agencies should review and modernize their rules to ensure they are fully protective of both groundwater and surface water. The findings also recommend additional field studies on methane leakage from hydrofractured wells to water reservoirs and the adoption of requirements for background water quality measurements to record existing methane levels in nearby water wells prior to drilling.
3. Creation of a Shale Gas Industry Operation organization committed to continuous improvement of best operating practices
A more systemic approach by the shale gas industry based on best practices -- recognized as improvements to techniques and methods over time based on measurement and field experience -- is an important way to achieve better operational and environmental outcomes. The report envisions the creation of a national organization, with external stakeholders, dedicated to continuous improvement of best practice through the development and diffusion of standards and the assessment of member compliance. The organization would likely work through regional subgroups.
4. Research and development (R&D) to improve safety and environmental performance
The report finds that, while the majority of shale gas R&D will be performed by the oil and gas industry, there is a role for the Federal government. The report recommends that the administration set an appropriate mission for shale gas R&D and level funding, with a particular focus on efficiency of water use and other improvements to enhance environmental objectives. Deutch said, "We are mindful of the nation's financial constraints. But we do see a key role that can be played by modest government support for R&D around environmental questions."
Access a release from DOE (click here). Access the complete 41-page 90-day draft report (click here). Access the SEAB website for extensive information including details on commenting, the Aug. 15 meeting, details of previous meetings, and a summary of comments (click here). Access a 5/5/11 release from DOE with additional background information on the committee members (click here). Access the complete 3-page charge to the group (click here). [*Energy/Frack]
Wednesday, August 10, 2011
Tuesday, August 09, 2011
The President said, "While we were working to improve the efficiency of cars and light-duty trucks, something interesting happened. We started getting letters asking that we do the same for medium and heavy-duty trucks. They were from the people who build, buy, and drive these trucks. And today, I'm proud to have the support of these companies as we announce the first-ever national policy to increase fuel efficiency and decrease greenhouse gas pollution from medium-and heavy-duty trucks."
DOT Secretary Ray LaHood said, "Thanks to the Obama Administration, for the first time in our history we have a common goal for increasing the fuel efficiency of the trucks that deliver our products, the vehicles we use at work, and the buses our children ride to school. These new standards will reduce fuel costs for businesses, encourage innovation in the manufacturing sector, and promote energy independence for America." EPA Administrator Lisa Jackson said, "This Administration is committed to protecting the air we breathe and cutting carbon pollution -- and programs like these ensure that we can serve those priorities while also reducing our dependence on imported oil and saving money for drivers. More efficient trucks on our highways and less pollution from the buses in our neighborhoods will allow us to breathe cleaner air and use less oil, providing a wide range of benefits to our health, our environment and our economy."
The White House indicated that under the comprehensive new national program, trucks and buses built in 2014 through 2018 will reduce oil consumption by a projected 530 million barrels and greenhouse gas (GHG) pollution by approximately 270 million metric tons. Like the recently proposed CAFE standards, this program -- which relies heavily on off-the-shelf technologies was developed in coordination with truck and engine manufacturers, fleet owners, the State of California, environmental groups and other stakeholders.
The joint DOT/EPA program will include a range of targets which are specific to the diverse vehicle types and purposes. Vehicles are divided into three major categories: combination tractors (semi-trucks), heavy-duty pickup trucks and vans, and vocational vehicles (like transit buses and refuse trucks). Within each of those categories, even more specific targets are laid out based on the design and purpose of the vehicle. The flexible structure allows serious but achievable fuel efficiency improvement goals charted for each year and for each vehicle category and type.
According to the White House, a semi-truck operator could pay for the technology upgrades in under a year and realize net savings of $73,000 through reduced fuel costs over the truck's useful life. These cost saving standards will also reduce emissions of harmful air pollutants like particulate matter, which can lead to asthma, heart attacks and premature death. By the 2018 model year, the program is expected to achieve significant savings relative to current levels, across vehicle types. Certain combination tractors -- commonly known as big-rigs or semi-trucks -- will be required to achieve up to approximately 20 percent reduction in fuel consumption and greenhouse gas emissions by model year 2018, saving up to 4 gallons of fuel for every 100 miles traveled.
For heavy-duty pickup trucks and vans, separate standards are required for gasoline-powered and diesel trucks. These vehicles will be required to achieve up to approximately 15 percent reduction in fuel consumption and greenhouse gas emissions by model year 2018. Under the finalized standards a typical gasoline or diesel powered heavy-duty pickup truck or van could save one gallon of fuel for every 100 miles traveled.
Vocational vehicles -- including delivery trucks, buses, and garbage trucks -- will be required to reduce fuel consumption and greenhouse gas emissions by approximately 10 percent by model year 2018. These trucks could save an average of one gallon of fuel for every 100 miles traveled.
Access a release from the White House (click here). Access complete detailed information including fact sheets, prepublication copy, modeling, regulatory impact analysis, response to comments and more from EPA's website (click here). Access more information from the NHTSA website (click here). [#Energy/Efficiency, #Climate, #Air]
Monday, August 08, 2011
The first section of the report, A Building Crisis, makes the case why U.S. infrastructure has fallen from first place in the World Economic Forum's 2005 economic competitiveness ranking to number 15 today. The second section of the report, Losing Ground to Our Global Competitors, takes an international look at transportation infrastructure and highlights certain themes that unify our competitors' plans while setting our transportation policies apart. The third section of the report, Recommendations for Reform, contains a clear set of recommendations for moving our economy-- and the case for strategic investment in infrastructureforward.
The report explains how international economic competitors are sprinting ahead of the U.S. and outlines the case for creating a blueprint to transition to a high-tech transportation network for the 21st century. The report also contains many sobering statistics detailing how the U.S. is falling behind including:
- U.S. infrastructure has fallen from first place in the World Economic Forum's 2005 economic competitiveness ranking to number 15 today;
- China now boasts six of the world's top ten ports -- and none of the top ten are located in the U.S. The Shanghai port now moves more container traffic a year than the top seven U.S. ports combined;
- The U.S. has the world's worst air traffic congestion -- a quarter of flights in the U.S. arrive more than 15 minutes late, and the national average for all delayed flights in the U.S. (about 56 minutes) is twice that of Europe's average;
- There are more than 15,000 miles of true high-speed rail in operation around the world essentially none of which is in the U.S.;
- The U.S. is one of the only leading nations without a national plan for public-private partnerships for infrastructure projects or a National Infrastructure Bank to finance large-scale projects and leverage private capital.
- Develop a long-term national infrastructure strategy that makes choices based on economics, not politics.
- Pass a robust transportation bill that focuses investment on projects that will increase economic return and mobility while reducing congestion and pollution. Such a bill will put Americans back to work and make the U.S. more competitive in the global economy.
- Be both innovative and realistic about how to pay (including the establishment of a National Infrastructure Bank) and looking at all long-term revenue generating options including congestion pricing, carbon auctions, fees based on miles traveled, and once the economy recovers an updated gas-tax.
- Promote accountability and innovation by setting clear criteria for all funding; encouraging innovation by states and the country's largest cities through competitive grants; and carefully auditing the results to ensure projects are completed on time, on budget, and yielding promised results.
Friday, August 05, 2011
Administrator Jackson said, "All too often, low-income, minority and Native Americans live in the shadows of our society's worst pollution, facing disproportionate health impacts and greater obstacles to economic growth in communities that can't attract businesses and new jobs. Expanding the conversation on environmentalism and working for environmental justice are some of my top priorities for the work of the EPA, and we're glad to have President Obama's leadership and the help of our federal partners in this important effort. Every agency has a unique and important role to play in ensuring that all communities receive the health and environmental protections they deserve. Our broad collaboration will mean real progress for overburdened communities."
Environmental justice means that all communities overburdened by pollution -- particularly minority, low income and tribal communities -- deserve the same degree of protection from environmental and health hazards, equal access to the Federal decision-making process, and a healthy environment in which to live, learn, and work.
According to a release, the signing of the EJ MOU is the latest in a series of steps the Obama Administration has taken to elevate the environmental justice conversation and address the inequities that may be present in some communities. Last September, Jackson and Sutley reconvened the Interagency Working Group on Environmental Justice (EJ IWG) for the first time in more than a decade. In December, at the White House Environmental Justice Forum, Cabinet Secretaries and other senior Administration officials met with more than 100 environmental justice leaders from across the country to engage advocates on issues that are affecting their communities, including reducing air pollution, addressing health disparities, and capitalizing on emerging clean energy job opportunities. The EJ MOU reflects the dialogue, concerns and commitments made at the forum and other public events. Since her appointment, Jackson has also joined congressional leaders across the country to tour impacted communities and hear residents' concerns.
The MOU advances agency responsibilities outlined in the 1994 Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations." The Executive Order directs each of the named Federal agencies to make environmental justice part of its mission and to work with the other agencies on environmental justice issues as members of the EJ IWG. The EJ MOU broadens the reach of the EJ IWG to include participant agencies not originally named in Executive Order 12898 and adopts an EJ IWG charter, which provides the workgroup with more structure and direction. It also formalizes the environmental justice commitments that agencies have made over the past year, providing a roadmap for agencies to better coordinate their efforts. Specific areas of focus include considering the environmental justice impacts of climate adaptation and commercial transportation, and strengthening environmental justice efforts under the National Environmental Policy Act and Title VI of the Civil Rights Act of 1964. The MOU also outlines processes and procedures to help overburdened communities more efficiently and effectively engage agencies as they make decisions.
The following agencies signed the EJ MOU: Environmental Protection Agency; White House Council on Environmental Quality; Department of Health and Human Services; Department of Justice; Department of Agriculture; Department of Commerce; Department of Defense; Department of Education; Department of Energy; Department of Homeland Security; Department of Housing and Urban Development; Department of Interior; Department of Labor; Department of Transportation; Department of Veterans Affairs; General Services Administration; and Small Business Administration.
Thursday, August 04, 2011
The report highlights a number of positive trends supporting future U.S. oil production growth, both onshore and offshore. However, the report also details a series of existing and emerging regulatory barriers facing the domestic industry. Among other things, the report finds that policymakers could do more to promote domestic oil production while safeguarding the environment, specifically through a series of pilot programs designed to leverage technology to minimize the industry's development footprint in frontier areas of the Outer Continental Shelf and the U.S. Arctic. The report argues that the current regulatory uncertainty surrounding hydraulic fracturing poses an emerging risk to production of both shale gas and shale liquids, and it calls on industry as well as state and federal regulators to provide a more comprehensive framework for development.
Top among the reasons to boost domestic oil production are reasons of economic and national security. According to the report, "From a national security perspective, increased self-reliance would help minimize the exposure of the United States to a crippling disruption in oil supplies brought about by turbulence in the Middle East or any other oil-supplying region. With the U.S. trade deficit in crude oil and petroleum products on pace to surpass $300 billion in 2011, producing more domestic oil would also minimize the transfer of U.S. wealth abroad."
General James Conway, former Commandant of the U.S. Marine Corps and member of SAFE's Energy Security Leadership Council said, "Without a question, it is in the United States' economic and national security interests to develop more of our own energy resources. For decades, our nation's energy policy has not been decided by Americans, but largely by state-owned oil exporting nations. Many of these countries are unstable, do not share our values, and in some cases, are outwardly hostile to the United States. It is time our leaders work in the short-term to develop more of our own oil resources as part of a comprehensive energy security strategy."
- Initiate a pilot program in cooperation with the State of Alaska to demonstrate extended reach drilling in the 1002 Area of the Arctic National Wildlife Refuge (ANWR).
- Implement comprehensive reform of the U.S. offshore regulatory approach, shifting from a rule-based to a goal-based approach.
- Increase funding for BOEMRE to attract highly trained engineers and enable BOEMRE to engage with operators on equal footing.
- Use the new regulatory approach to open frontier areas and use the experience of frontier areas to refine the new regulatory approach.
- Implement distance-from-shore provisions designed to minimize the footprint of offshore oil and gas development in all frontier areas.
- Initiate an "inventory-to-lease" program in frontier areas of the Outer Continental Shelf, subject to goal-based regulation.
- Implement a system of progressive royalties for new OCS leases.
- Create loan guarantees for the construction of CO2 pipelines from major economic and industrial centers to regions populated with oil and gas fields for use in EOR projects.
- Establish a comprehensive approach to ensure regulatory stability for unconventional oil and gas production while also giving operators the certainty to move forward.