CFACT Collegians Fuel Federal Energy DebateNate MyersMay 20, 2026
CFACT Collegians are once again stepping into the federal rulemaking process, urging agencies to choose practical, science-based regulations over red tape that punishes American energy production.
Taylor Elliott of Lipscomb University in Tennessee, Thien Nguyen of the University of Texas at Austin, and Zach Lochard of Southern Illinois University Carbondale each weighed in on a different federal proposal. Taken together, their comments make a clear case for CFACT’s approach: protect the environment with human prosperity kept paramount, modernize and deregulate outdated or biased rules, and make America energy independent.
Taylor Elliott called for balanced marine mammal protections and regulatory support for offshore energy production:
“My name is Taylor Elliott, and I am an undergraduate student at Lipscomb University, writing on behalf of the Committee for a Constructive Tomorrow (CFACT), an organization committed to promoting responsible environmental stewardship and advancing domestic energy production. We believe NOAA’s National Marine Fisheries Service (NMFS) proposal to reimplement incidental take regulations for offshore energy and fisheries research activities is necessary and reasonable. As an organization, we believe that maintaining this framework under the Marine Mammal Protection Act (MMPA) should proceed responsibly.
There are already strong protections by the MMPA that require any authorized incidental take to have only a negligible impact on the marine mammal population and will not adversely affect a species long-term survival. These safeguards which include mitigation measures like exclusion zones, onboard protected species observers, and real-time shutdown protocols, all work to limit negative impacts on marine life.
Our organization recognizes that the Marine Mammal Protection Act (MMPA) provides strong protections that require all authorized incidental take to protect Marine Mammel’s long-term survival. Data about previous incidental take shows that actual injuries are extremely rare and that the majority of “takes” involve temporary behavioral disturbances and not physical harm. This proves that energy development and marine conservation can coexist with a protective, regulatory framework.
That being said, CFACT urges NMFS to continue maintaining an incidental take framework that protects marine life. However, we would caution against expanding regulations beyond what would be supported by scientific data in order to be overly cautious. The regulations as is seem to be science-based, risk informed that ensures that the objectives of the MMPA are met and support reasonable domestic energy conservation.”
Thien Nguyen supported a pipeline safety modernization rule that reflects today’s engineering capabilities:
“Dear Pipeline and Hazardous Materials Safety Administration,
My name is Thien Nguyen, and I submit this comment in support of the proposed integrity management alternative for addressing class location changes in gas transmission pipelines.
The historical class location system was established at a time when operators did not have access to the sophisticated diagnostic tools available today. Mandatory pressure reductions, pipe replacement, or hydrostatic testing were appropriate safety measures in the absence of advanced inspection capabilities. In contrast, modern integrity management programs enable operators to detect corrosion, cracking, seam issues, and material defects with high precision through validated inline inspection technologies.
This proposal maintains robust safety standards. Only eligible Class 3 transmission segments may utilize the alternative, and strict exclusions apply to high-risk pipe characteristics. Operators are required to incorporate these segments into High Consequence Area programs, adhere to rigorous assessment schedules, implement appropriate mitigation measures, and comply with ongoing operational requirements. Any in-service leak or rupture disqualifies a segment from continued participation. These safeguards demonstrate that the rule focuses on modernization rather than deregulation.
The economic and environmental impacts of this proposal are substantial. Avoiding unnecessary pipeline replacement reduces construction-related disturbances and methane emissions from blowdowns. This approach prevents avoidable service interruptions and supports reliable energy delivery to communities experiencing population growth. A risk-informed framework enables capital resources to be allocated toward genuine safety improvements rather than redundant infrastructure replacement.
Public safety must remain the foremost priority; however, regulatory policy should also reflect current engineering capabilities. This rule achieves an appropriate balance among safety, environmental accountability, and infrastructure reliability by permitting modern integrity management tools to supplement outdated prescriptive mandates.
I respectfully urge PHMSA to advance this modernization of pipeline safety oversight.
Lastly,Zach Lochard defended offshore energy development and a risk-based approach to financial assurance:
“To Whom It May Concern,
I write in strong support of BOEM’s proposal to modernize and adopt a more risk-based approach to financial assurance requirements for offshore oil, gas, and sulfur operations on the Outer Continental Shelf.
For too long, excessive and one-size-fits-all bonding requirements have tied up capital, discouraged investment, and slowed down American energy production. These overly burdensome rules don’t just hurt companies; they hurt American workers, American energy independence, and ultimately American families who pay the price through higher energy costs.
This proposal is a step in the right direction.
A risk-based system is common sense. It ensures that financial assurance requirements are aligned with actual, measurable risk rather than arbitrary thresholds or outdated assumptions. Companies with strong financial standing and a proven track record should not be penalized with unnecessary supplemental bonding requirements that restrict their ability to invest, expand, and produce.
Let’s be clear: we can protect the environment and promote energy development at the same time. These goals are not mutually exclusive. BOEM should absolutely maintain requirements that ensure proper cleanup, decommissioning, and environmental safeguards. But those requirements must be grounded in reality, not inflated to the point where they become a barrier to entry and growth.
At a time when America should be doubling down on domestic energy production, reducing reliance on foreign adversaries, and strengthening our economic position, we cannot afford policies that choke off investment in our own resources.
This rule moves us closer to a system that is fair, rational, and aligned with America’s strategic interests.
I strongly encourage BOEM to finalize this proposal and resist any pressure to return to overly restrictive and unnecessary financial assurance frameworks.
Put simply: unleash American energy, trust responsible operators, and stop penalizing success with excessive regulation.
CFACT Collegians are once again stepping into the federal rulemaking process, urging agencies to choose practical, science-based regulations over red tape that punishes American energy production.
Taylor Elliott of Lipscomb University in Tennessee, Thien Nguyen of the University of Texas at Austin, and Zach Lochard of Southern Illinois University Carbondale each weighed in on a different federal proposal. Taken together, their comments make a clear case for CFACT’s approach: protect the environment with human prosperity kept paramount, modernize and deregulate outdated or biased rules, and make America energy independent.
Taylor Elliott called for balanced marine mammal protections and regulatory support for offshore energy production:
“My name is Taylor Elliott, and I am an undergraduate student at Lipscomb University, writing on behalf of the Committee for a Constructive Tomorrow (CFACT), an organization committed to promoting responsible environmental stewardship and advancing domestic energy production. We believe NOAA’s National Marine Fisheries Service (NMFS) proposal to reimplement incidental take regulations for offshore energy and fisheries research activities is necessary and reasonable. As an organization, we believe that maintaining this framework under the Marine Mammal Protection Act (MMPA) should proceed responsibly.
There are already strong protections by the MMPA that require any authorized incidental take to have only a negligible impact on the marine mammal population and will not adversely affect a species long-term survival. These safeguards which include mitigation measures like exclusion zones, onboard protected species observers, and real-time shutdown protocols, all work to limit negative impacts on marine life.
Our organization recognizes that the Marine Mammal Protection Act (MMPA) provides strong protections that require all authorized incidental take to protect Marine Mammel’s long-term survival. Data about previous incidental take shows that actual injuries are extremely rare and that the majority of “takes” involve temporary behavioral disturbances and not physical harm. This proves that energy development and marine conservation can coexist with a protective, regulatory framework.
That being said, CFACT urges NMFS to continue maintaining an incidental take framework that protects marine life. However, we would caution against expanding regulations beyond what would be supported by scientific data in order to be overly cautious. The regulations as is seem to be science-based, risk informed that ensures that the objectives of the MMPA are met and support reasonable domestic energy conservation.”
Thien Nguyen supported a pipeline safety modernization rule that reflects today’s engineering capabilities:
“Dear Pipeline and Hazardous Materials Safety Administration,
My name is Thien Nguyen, and I submit this comment in support of the proposed integrity management alternative for addressing class location changes in gas transmission pipelines.
The historical class location system was established at a time when operators did not have access to the sophisticated diagnostic tools available today. Mandatory pressure reductions, pipe replacement, or hydrostatic testing were appropriate safety measures in the absence of advanced inspection capabilities. In contrast, modern integrity management programs enable operators to detect corrosion, cracking, seam issues, and material defects with high precision through validated inline inspection technologies.
This proposal maintains robust safety standards. Only eligible Class 3 transmission segments may utilize the alternative, and strict exclusions apply to high-risk pipe characteristics. Operators are required to incorporate these segments into High Consequence Area programs, adhere to rigorous assessment schedules, implement appropriate mitigation measures, and comply with ongoing operational requirements. Any in-service leak or rupture disqualifies a segment from continued participation. These safeguards demonstrate that the rule focuses on modernization rather than deregulation.
The economic and environmental impacts of this proposal are substantial. Avoiding unnecessary pipeline replacement reduces construction-related disturbances and methane emissions from blowdowns. This approach prevents avoidable service interruptions and supports reliable energy delivery to communities experiencing population growth. A risk-informed framework enables capital resources to be allocated toward genuine safety improvements rather than redundant infrastructure replacement.
Public safety must remain the foremost priority; however, regulatory policy should also reflect current engineering capabilities. This rule achieves an appropriate balance among safety, environmental accountability, and infrastructure reliability by permitting modern integrity management tools to supplement outdated prescriptive mandates.
I respectfully urge PHMSA to advance this modernization of pipeline safety oversight.
Lastly, Zach Lochard defended offshore energy development and a risk-based approach to financial assurance:
“To Whom It May Concern,
I write in strong support of BOEM’s proposal to modernize and adopt a more risk-based approach to financial assurance requirements for offshore oil, gas, and sulfur operations on the Outer Continental Shelf.
For too long, excessive and one-size-fits-all bonding requirements have tied up capital, discouraged investment, and slowed down American energy production. These overly burdensome rules don’t just hurt companies; they hurt American workers, American energy independence, and ultimately American families who pay the price through higher energy costs.
This proposal is a step in the right direction.
A risk-based system is common sense. It ensures that financial assurance requirements are aligned with actual, measurable risk rather than arbitrary thresholds or outdated assumptions. Companies with strong financial standing and a proven track record should not be penalized with unnecessary supplemental bonding requirements that restrict their ability to invest, expand, and produce.
Let’s be clear: we can protect the environment and promote energy development at the same time. These goals are not mutually exclusive. BOEM should absolutely maintain requirements that ensure proper cleanup, decommissioning, and environmental safeguards. But those requirements must be grounded in reality, not inflated to the point where they become a barrier to entry and growth.
At a time when America should be doubling down on domestic energy production, reducing reliance on foreign adversaries, and strengthening our economic position, we cannot afford policies that choke off investment in our own resources.
This rule moves us closer to a system that is fair, rational, and aligned with America’s strategic interests.
I strongly encourage BOEM to finalize this proposal and resist any pressure to return to overly restrictive and unnecessary financial assurance frameworks.
Put simply: unleash American energy, trust responsible operators, and stop penalizing success with excessive regulation.
America should produce its own energy, period!
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