On June 6, APGA submitted comments as part of a coalition of industry trade associations in response to the Office of Management and Budget’s (OMB) proposed changes to the public engagement process for rulemakings currently under review by the agency. These changes were released concurrently with the Administration’s proposed changes to OMB Circular A-4, which provides guidance to all federal agencies on how to conduct cost-benefit analyses for rulemakings.
These proposed changes, paired with Executive Order 12866 (Regulatory Planning and Review), are of utmost importance to APGA and its members because of its potential impact on regulations coming out of the Pipeline and Hazardous Materials Safety Administration (PHMSA), the Federal Energy Regulatory Commission (FERC), the Department of Energy (DOE), and all other federal agencies. If finalized, federal agencies would be provided with an unprecedented level of deference, which would lessen the burden for them to promulgate rules that would have otherwise been limited by excessive costs. For more background on these proposed changes, please see an earlier APGA Community post here.
APGA joined the coalition in requesting an extension in the comment period for both the proposed changes to Circular A-4 and the guidance for public engagement. However, OMB elected to only extend the comment period for the proposed changes to Circular A-4’s cost-benefit analysis guidance.
View APGA's comments here.
For any members that are interested in also supporting APGA’s efforts to oppose these changes, please consider submitting your own comment letter by June 20. Several members – including Middle Tennessee, the Municipal Gas Authority of Georgia, and Jackson Energy Authority – have already submitted their own comments. To support your engagement, APGA staff has pulled together a form letter for use. More information is available here.
For questions on this article, please contact Stuart Saulters of APGA staff by phone at 202-802-0493 or by email at ssaulters@apga.org.