History of Engagement
Our approach to public policy engagement on climate change has evolved. However, we remain consistent in our view that market-based solutions at national and global levels, rather than a patchwork of less effective regulatory approaches, are most likely to be effective in reducing GHG emissions.
Shortly after the merger of Conoco and Phillips Petroleum in 2003, we published our first global climate change position. Since then, we have consistently used our Sustainability Report to detail our commitments, priorities and actions. We also first participated in the Carbon Disclosure Project (now CDP) questionnaire in 2003.
In 2004, we described actions that we would be taking to address climate change, including:
- Assessing data
- Developing objectives to reduce GHG emissions
- Improving operational efficiency
- Developing climate change considerations for project planning and approval processes
- Engaging in discussions on climate change through the International Petroleum Industry Environmental Conservation Association (now IPIECA)
- Joining the International Emissions Trading Association (IETA)
In 2005, we began trading in the European Union ETS.
Through our membership in the U.S. Climate Action Partnership (USCAP) beginning in 2007, we actively participated in efforts to design an effective legislative approach.
In 2008, we adopted and published our first Climate Change Action Plan to systematically address climate change risk.
In June 2009, the American Clean Energy and Security Act of 2009 (HR2454) (Waxman-Markey) bill passed the House of Representatives. Although the USCAP Blueprint for Legislative Action was considered influential in the design of the legislation, we had serious concerns about some of the detailed elements in the bill. Following passage of the House bill, our focus turned to addressing issues of concern in the Senate version of the legislation. In order to intensify our company’s focus and resources on addressing the key issues, including the important role that natural gas can play in reducing U.S. GHG emissions, we announced in February 2010 that the company would not be renewing our membership in USCAP.
Through this more direct engagement, we were successful in helping to develop draft legislation that incorporated a more equitable approach to energy sectors while maintaining environmental effectiveness. We issued a statement regarding the draft legislation introduced in the Senate in May 2010.
Since 2010, we’ve continued to work toward approaches that are practical and effective, including active participation in dialogue with trade associations like the American Petroleum Institute (API), industry partners and the government to advocate smart policy solutions.
Recent regulatory engagement
Collaborating with a broad range of stakeholders on effective climate change policy and GHG emissions solutions is key to solving the climate change challenge.
In 2014, we publicly supported the Gas Capture Plan in North Dakota, now required, which took a pro-active approach to flare gas reduction. We entered into agreements with pipeline companies to ensure that required gathering infrastructure was available when needed in order to reduce emissions.
In 2016, we supported the U.S. Bureau of Land Management Onshore Order 1, electronic filings, as the proposed changes reduced work and errors and sped up response time for both industry and the government.
In 2016, the U.S. Bureau of Land Management (BLM) proposed a series of Onshore Orders. After careful review, ConocoPhillips opposed Onshore Order 9, the proposed Venting and Flaring rule, based on the conclusion that the BLM was overreaching their authority and the proposal created a duplication of federal authority with EPA. Our comments to the BLM included suggestions to remove many of the duplicative requirements. While we opposed many of the requirements in Onshore Order 9, we did suggest some changes to certain proposed requirements. For example, we agreed that the limits for royalty-free flaring should be changed and gave recommendations for the limits.
Since 2018, we have been a member of the Energy Advance Center (EAC), a voluntary association of energy and energy-related organizations dedicated to advancing the development and deployment of carbon capture, utilization and storage to achieve a cleaner energy profile and improve U.S. economic security. In 2018, Congress passed the Furthering Carbon Capture, Utilization, Technology, Underground Storage, and Reduced Emissions Act to enhance the 45Q tax credit to further incentivize carbon capture and storage technology deployment in the United States. The primary issue with the 45Q tax credit is the interpretation of what constitutes secure geological storage (SGS). In particular, we support the adoption of a commercially reasonable ISO standard to demonstrate secure geological storage in the context of captured carbon dioxide that gets sequestered underground for enhanced oil recovery projects. The standard should establish criteria for transparency and assurance that carbon dioxide removal is achieved. We also support self-verification of compliance with the ISO standard given that our tax officer would attest to satisfying the requirements of 45Q under penalties of perjury.
Recent legislative engagement
In 2019, we worked within the broad coalition of Climate Leadership Council members to better define details of the overarching implementation plan. That included work on topics such as carbon price escalation rates, points of taxation, regulatory backstop provisions, high energy-cost region challenges and a border carbon adjustment. While the policy work continues with CLC members, the results of that engagement are reflected in the more detailed CLC plan released in early 2020. We also engaged with members of congress directly and through Americans For Carbon Dividends. This included reviewing several proposed climate bills and continuing to offer technical feedback on those bills to elected representatives and their staff. The company remains engaged with representatives from both sides of the political spectrum.
In 2014, both the oil industry and environmental leaders in Alberta, Canada, realized they were at an impasse as public dialogue on the oil sands, pipelines and climate change had descended into a polarized debate. The provincial government wanted help to achieve their climate change policy commitments, and industry and environmental organizations realized it was time to try something different: to participate in a provincial climate policy that would recognize the importance of industry competitiveness. The groups were able to work together and agree on recommendations that the Alberta government included in its Climate Leadership Plan.
One element of the Climate Leadership Plan is the Emissions Limit for oil sands. In 2016, through our progressive work with leading environmental groups in Canada, we secured a seat on the Oil Sands Advisory Group (OSAG), one of only seven industry seats. Designed to advise the government on the implementation of the limit and other oil sands environmental issues, the OSAG includes members from industry, environmental organizations, and indigenous and non-indigenous peoples. The primary focus of the group is to consider how to implement the 100 million tonnes of CO₂ equivalent per year GHG emissions limit for the oil sands industry.