Comprehensive Permitting Reform Now Will Probably Not Reduce Greenhouse Gas Emissions

Waqar Qureshi

58 Posts

Based on the Lobby Training #1 held on October 30, CCL appears to be focusing solely on the electricity sector when justifying support for comprehensive permitting reform. The core message seems to be: support comprehensive permitting reform now because renewables will benefit more than fossil fuel power generation. However, this approach leaves unaddressed the other 65% of the energy system, which is almost entirely fossil fuel-based. Critical questions remain: What will happen in those sectors? And even within the electricity sector, will the benefits be as large as CCL hopes? Will permitting reform actually reduce overall greenhouse gas emissions?

There are multiple reasons to believe that comprehensive permitting reform enacted now will result in increased, not decreased, GHG emissions.

The Political and Economic Context

Beginning with the broadest argument: our current President and Congress have chosen dominance in fossil fuel production and consumption as their strategy for achieving energy and national security. This is accompanied by ideological opposition to renewables from the President and the right wing of his party. In this political environment, it seems unlikely that any permitting reform package would reduce U.S. fossil fuel consumption and production—which is essentially what needs to happen to reduce GHG emissions.

Consider also that one of the biggest advocates for comprehensive permitting reform is the U.S. oil and gas industry. The industry's main trade organization, the American Petroleum Institute (API), is in full-throated support—to the extent that it has purchased advertising time on New York Times podcasts touting permitting reform. While the API and its member companies could mistakenly support legislation that reduces production and use of their product, this seems highly unlikely.

What the Oil and Gas Industry Expects

Comments from Mike Sommers, API CEO, in this Politico Energy Podcast illustrate what the industry expects permitting reform to deliver. Sommers cites examples of oil and gas pipeline projects that were denied permits or delayed:

The industry wanted to get Keystone heavy oil pipeline built (was permitted, permits cancelled by Biden in 2021), Williams company is restarting efforts to build the Constitution gas pipeline and the Northeast (gas) Supply Enhancement project, Mountain Valley pipeline cost $9B instead of $3B because of delays. Atlantic Coast pipeline was cancelled.

The clear implication: with permitting reform, these projects could be revived or similar large-scale projects initiated, with greater certainty that they will not be delayed or cancelled.

Wood Mackenzie (WoodMac), a leading firm providing research and data services to the global energy industry, recently published an analysis: How LNG and power are shaping US gas pipeline development. The report states that over the past 15 years, judicial and regulatory scrutiny and challenges in obtaining a "social license to operate" have adversely affected upstream investment and regional price stability. "Fortunately, permitting reform and other supportive policy measures look set to make the situation easier and unlock future pipeline buildout." WoodMac is currently tracking $50 billion worth of projects that would add up to 8,800 miles of new gas pipeline in the U.S.

More data on gas pipelines is available at this FERC website of major gas pipeline projects pending approval. Also see the Addendum below for examples of gas pipelines awaiting federal or state permits.

The Emissions Impact of Expanded Pipeline Infrastructure

Greater certainty in developing and constructing gas pipelines means more gas can be produced and distributed to existing and new markets across residential and commercial heating, and industrial sectors. New gas fields can be connected more easily to replace depleting reservoirs. More gas means lower prices, expanded distribution means new customers—and all of this means greater consumption and increased GHG emissions.

Yes, the industry raises familiar arguments about how gas could reduce emissions, but these cases are now weaker than before:

New gas plants replacing coal-fired power domestically: The administration is extending coal power plant lifetimes, and new gas plants increasingly compete with solar and wind power rather than coal.

Exported LNG replacing coal-fired plants overseas: There is now significantly more renewable electricity globally, meaning new gas competes with new renewables, not just coal. Furthermore, the administration is aggressively pushing the EU to take more U.S. LNG, even attempting to strong-arm the EU into weakening its climate rules.

Natural gas displacing heating oil in the Northeast U.S.: This effect will be undermined by increased gas supply reducing the currently high Northeast gas prices, which will actually stimulate greater overall consumption.

Problems with the Electricity Sector Focus

Slide 17 of the October 30 training states that "more than 95% of projects waiting in line are clean energy." This statement appears to be inadvertently broad. It likely intended to say that 95% of generation capacity waiting in interconnection queues in the electricity sector is clean energy. Outside the electricity sector, nearly 100% of energy projects waiting for permits are fossil fuel-based.

Even if we focus on the most favorable sector, electricity, CCL's argument appears to be that comprehensive permitting reform will benefit renewables far more than gas-fired generation, making it good for the climate. However, there's a fundamental problem with this reasoning: it doesn't matter how much renewable energy is added if there is any net increase in fossil-fired generation. GHG emissions will rise with the incremental fossil generation (setting aside the nuanced case of gas substituting for coal).

Additionally, the implied 95-to-5 ratio of renewables to fossil generation is likely overly optimistic for several reasons:

Batteries are misclassified: Slide 20 includes batteries as a generating source. They are energy storage, not generation.
Capacity factors matter: Slide 20 doesn't account for capacity factors, which are generally higher for gas-fired generation than for renewables.
Manufacturing constraints show a sign of easing: New gas-fired generation is currently constrained by gas turbine manufacturing capacity. In a previous post in July, I noted that manufacturers would ramp up production given sufficient certainty. I expected this to take perhaps five years, so was surprised when Mitsubishi Heavy Industries announced a doubling of capacity just a month or two later. The bottleneck still exists, but industry is beginning to respond as it typically does.
Renewable constraints extend beyond permitting: Renewables face obstacles beyond transmission line permitting, including growing local opposition to wind and solar projects.

Moreover, for comprehensive permitting reform to benefit the climate, reductions in fossil-fired electricity generation would need to be large enough to offset all potential increases in fossil fuel combustion throughout the rest of the energy system. This seems highly unlikely.

Recommended Approach for Fall Lobbying

In my opinion, CCL should:

Not ask for comprehensive permitting reform now because it will not benefit the climate. Instead, ask for Clean Energy Permitting Reform, which is the actual wording of CCL's focus area. We should advocate for streamlined permitting, community engagement, and judicial reform within the scope of:

Transmission lines
Geothermal
Nuclear
Other clean energy technologies

For Democrats: Clean Energy Permitting Reform supports climate goals, reliability, and affordability.

For Republicans: Clean Energy Permitting Reform enhances affordability, reliability, and international competitiveness (giving us a chance of catching up in future energy technologies).

We should be prepared to withhold support from any permitting reform package if it would increase greenhouse gas emissions. We should recognize this could be difficult to do because such a package would have bipartisan support and, in our economic system (where pollution remains unpriced), it would boost jobs and GDP and so would have the support of much of industry and many sectors of the public. However, it would not be consistent with CCL's reason for existing if it were to support legislation that increased carbon pollution.

Addendum: Examples of Gas Pipelines Awaiting Federal or State Permits

1. Northeast Supply Enhancement (NESE)

Owner: Williams Companies (Transcontinental Gas Pipeline Company/Transco)
Location: Pennsylvania through New Jersey to New York (offshore Rockaway Peninsula, Queens)
Purpose: Provide 400,000 dekatherms per day of incremental capacity to serve the New York City area
Status: Project was cancelled in 2020 after failing to obtain needed state permits, but Williams is reviving construction. FERC re-approved the project with a targeted in-service date in Q4 2027, but still needs state water quality permits from New York and New Jersey

2. Regional Energy Access Expansion

Owner: Williams Companies
Location: Pennsylvania to New Jersey
Purpose: Natural gas pipeline expansion
Status: Project was cancelled in 2024 but Williams is reviving construction, pending state permits

3. Rio Bravo Pipeline

Owner: Enbridge (joint venture)
Location: Texas (Cameron County area)
Purpose: Support Rio Grande LNG export terminal
Status: FERC issued draft supplemental environmental impact statement in March 2025; construction would begin in 2025 with target in-service date during second half of 2026, pending approval and receipt of all necessary permits

4. MVP Boost

Owner: Mountain Valley Pipeline
Location: Virginia to North Carolina (from Pittsylvania County)
Purpose: Transport natural gas from Pittsylvania County into North Carolina
Status: In June 2025, FERC held public scoping sessions as part of its environmental review of the planned project

5. South System Expansion 4 (SSE4)

Owner: Southern Natural Gas Company, LLC and Elba Express Company, LLC
Location: Mississippi region (multiple states)
Purpose: Natural gas transmission capacity expansion
Status: FERC issued Notice of Intent to Prepare Environmental Impact Statement in September 2025

6. Mississippi Crossing Project (MSX)

Owner: Tennessee Gas Pipeline Company, LLC
Location: Mississippi region
Purpose: Natural gas transmission
Status: FERC issued Notice of Intent to Prepare Environmental Impact Statement in September 2025

6day(s)

4 Replies

Dana Nuccitelli

2747 Posts

Hi @Waqar Qureshi. CCL will only support bills that reduce climate pollution. That's why we were happy to see the expert modeling of the Energy Permitting Reform Act last year, which found that it would have likely substantially reduced emissions. Electrical transmission capacity is a major bottleneck to adding clean energy to the grid, and the modeling found that the transmission provisions in the bill would have reduced emissions by 6.5 to 14.3 billion tons, which is huge (for context, recall that the retained provisions from the IRA will reduce emissions by around 1 billion tons).

That number will likely change with the phase-out of the solar and wind tax credits, but nevertheless should remain quite large, depending on what the transmission provisions of a new permitting reform bill look like.

A comprehensive bill will also streamline the permitting process for other types of energy infrastructure, including gas generation and pipelines. But those will still be constrained. Gas turbine makers are still hesitant to increase manufacturing capacity too much because they know policies and demand can change and they don't want to strand investment assets, for example. As for gas pipelines, we already have over 2.6 million miles of those in the US, so adding a few thousand more miles wouldn't represent a big capacity change. And US oil demand is pretty stagnant, with meaningful growth in zero- and low-emissions vehicles, so oil pipelines won't make a lot of difference either.

That's not to say that permitting reform won't benefit fossil fuels too, but there are a lot of reasons to believe it benefit clean energy more, and thus have a positive net influence in terms of reducing climate pollution. But we'll of course evaluate the details of any proposed permitting reform legislation before taking a stance on it. Right now we're just asking MOCs to engage in negotiations, which will help ensure it has the important provisions to reduce climate pollution.

5day(s)

Peter Joseph

387 Posts

@Dana Nuccitelli, @Waqar Qureshi Thank you both this richly informative discussion. As we prep to ask our MoC, the ranking D on the House Natural Resources Committee, perhaps you can address his concern that the current administration's open hostility to clean energy will skew the permitting reform process towards favoring dirty energy sources, as noted in Waqar's superb essay. This would be a case of “blowback” which would not enhance CCL's standing.

5day(s)

Dana Nuccitelli

2747 Posts

Hi @Peter Joseph. Yes indeed, a permitting reform bill will have to include language to overcome executive meddling in the permitting process. That's actually an idea with bipartisan support, since Republicans were angry that the Biden administration froze LNG export terminal permits and Democrats are angry that the Trump administration is blocking clean energy permits. Here's what Senator Whitehouse said about it a couple days ago:

"it would contain safeguards to protect against more abuse and illegality by the Trump administration in the energy space. There’s language kicking around, but it’s not too far.”

5day(s)

David Kline

377 Posts

@Dana Nuccitelli:

Hi @Waqar Qureshi. CCL will only support bills that reduce climate pollution.

I tracked down the training that elaborates on CCL's position in that regard. Here's what it says:

CCL advocates for ‘good permitting reform’ that maximizes benefits for the climate and protects health and safety in American communities. It is important that any legislation do two things:

Drives down carbon pollution by speeding up approval for good clean energy projects
Protects the health and safety of American people and communities

To achieve those goals, we are interested in policies that:

Add to America’s capacity to transmit clean electricity
Speed up the approval of clean energy projects that are waiting to be built
Allow communities to make their voices heard on the environmental and other impacts of proposed energy projects.

2day(s)

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Comprehensive Permitting Reform Now Will Probably Not Reduce Greenhouse Gas Emissions