NSPE Executive Director Mark Golden testified at an EPA hearing on July 10 to fight efforts to stop a critical final rule on oil and natural gas emissions that require a professional engineer to perform critical functions to meet performance standards. In his comments to the EPA, Golden said, “There is no reason or basis for displacing properly enacted final rules at this time. And to stay the rules requiring involvement of licensed professional engineers creates real and unnecessary risks to the public health, safety, and welfare in the interim.”
In the present rules, Golden added, “the EPA asserts a strong, well-reasoned, and well-supported rationale for the need for licensed professional engineers to be in responsible charge on all engineering projects, both in an independent third-party capacity, as well as in an in-house role. A substantial public record was created and considered by the agency in finalizing the rules that are subject to the proposed stays. More than 7,000 public comments were received and more than 600 documents were made part of the record of the final rule.”
NSPE, therefore, believes the requirements are sound and based not only upon a full and adequate public record, but also complete legal, judicial, and economic review. This includes a finding by the US Court of Appeals for the District of Columbia that “a lengthy discussion of the ‘costs and benefits’ went into the rule, including both industry and public comments on the PE certification requirements.”
NSPE strongly urges the EPA to enforce the current requirements until and unless a new rulemaking is undertaken and will be fully engaged in the ongoing proceedings.