Texas Greenhouse Gas Rules: Upcoming Hearing and End of Comment Period
Monday, December 2, 2013
As we discussed in an October post, the Texas Commission on Environmental Quality (TCEQ) has proposed rules to create a greenhouse gas (GHG) permitting program for the state of Texas and take over permitting authority from the U.S. Environmental Protection Agency (EPA). Because it hopes to make the transition as quickly as possible, TCEQ is using a streamlined public participation process, which is soon coming to an end. At 2:00 pm on December 5th, TCEQ will hold its only public hearing on the proposal (see notice here). TCEQ will then continue to accept written comments on the rules through December 9th.
If your company would like to see a change to—or particularly supports—some aspect of the proposed rules, it is important to participate in the hearing or submit written comments before the deadline. It is not clear whether these proposed rules will be controversial, but it is possible, and participating during the comment period can help strengthen one’s position before the Commission or a court, should a challenge be brought.
Tim Wilkins is the head of Bracewell's firm-wide Environmental and Natural Resources practice group. Tim represents large companies that rely on him for strategic environmental permitting assistance, the defense of environmental enforcement actions, and assistance with the environmental aspects of major transactions. He is a nationally-recognized leader in environmental auditing, having overseen environmental compliance audits involving thousands of locations, handled hundreds of environmental audit disclosures, and pioneered the development and use of U.S. EPA's audit...