TCEQ Commissioner Emily Lindley addressed the membership of the Permian Basin Petroleum Association (PBPA) in the Midland Petroleum Club as keynote speaker for its March 17 luncheon.
The Texas Commission on Environmental Quality is the environmental agency for the state. TCEQ employs approximately 2,800 workers who are located in 16 regional offices around Texas and also in the agency’s central office in Austin. TCEQ strives to protect the state’s public health and natural resources in a manner consistent with sustainable economic development. Its goal is clean air, clean water, and safe management of waste.
During her time with the TCEQ, Commissioner Emily Lindley, a Midland native, has worked closely with the International Boundary Water Commission on compliance with the 1944 treaty between Mexico and the United States relating to the Colorado River, the Tijuana rivers, and the Rio Grande. She has also been involved in the agency’s delegation from the United States Environmental Protection Agency (EPA) regarding permits for discharges of produced water, hydrostatic test water, and gas plant effluent into water in the state resulting from certain oil and gas activities under the National Pollutant Discharge Elimination System (NPDES) program. And Commissioner Lindley also interacts with the energy sector to create awareness of TCEQ permitting regulations.
We share, below, Commissioner Lindley’s remarks from her talk.
Emily Lindley:
Emily Lindley
“Thank you. It is great to be here. I always love coming to Midland, My parents no longer live here, but I still have some family here. Before I really jump into things, I always like to introduce Morgan Johnson. Morgan is my senior advisor. And so, if we have time for a Q&A or if some us get to stand around and visit afterwards, she’s really the main person you need to talk to. So I just want to make sure y’all know who she is. She’s my attorney, keeps me out of trouble, all that good stuff.”
On What They Do
“So with that, let me say a little about TCEQ, about who we are, because everyone knows the Railroad Commission really well, as you should. That’s your main regulator in Texas. But I think we are a little interesting as well. In the state, Texas natural resource programs were created about the turn of the century, the 20th century. [laughter] And that all came out initially because of concerns about water. So water resources, water rights, were the main focus of the natural resource programs back then. Kind of what was happening with the nation—there was a parallel of what was happening in Texas. And a state Natural Resource Commission was created about the mid century at the federal level and a little bit later here in Texas and that included not just water, but we started doing things like air and looking at the regulation of hazardous waste and non-hazardous waste.
“So then in early Nineties, the Texas legislature moved to make the Natural Resource Agency a bigger deal and gave them more authority as far as looking after the protection of our natural resources. And so they combined at the time, the Air Commission and the Water Commission and the Texas Conservation Commission was created. That acronym is TNRCC. And so that was created in 1993. We were renamed in 2001 to the Texas Commission on Environmental Quality because TNRCC was pronounced Train Wreck. [laughter] So we were renamed the TCEQ, because that sounds better.
“We are governed by three appointees that the governor appoints. We serve—kind of like the Railroad Commission—staggered terms. And so all of our terms are usually about six years. And I was appointed August 2018, so I’ve got a few more years.
“The main reason you are [likely] ever to interact with the TCEQ is if you are emitting anything. So anything into the air, you probably need to be talking with us. Venting, flaring, that kind of stuff. We also now are regulating the [issuance of] discharge permits of wastewater related to oil and gas activities… Another thing I want you to know about us, and something that keeps us probably the most busy, is that TCEQ, when it comes to natural resources, is probably more engaged with EPA [than any other state agency]. We are talking to them daily and, well, sometimes we get along, and sometimes we don’t.
“Yes, we disagree with EPA on a lot of things. But, by and large, our staff and theirs do get along because we’ve got to move things along. And so while we struggle agreeing with them on a lot of issues, we do agree with them on some. And that’s how things get done. Because we are able to come to the table and a lot of times put the politics aside. So I’ll just mention that some of the things that we’re talking about a lot with them right now are the methane rule and Waters of the United States.”
“EPA Region Six (which covers the Permian Basin) has a new administrator. She was named back in December. One thing I will mention, I did actually work at EPA very briefly for four months almost to the day. So I had, I started at the TCEQ in January 2008. I had had no desire to go work at EPA. Talked to a few friends, talked my spouse, they all said, you should give it a shot. You could learn a lot of things. And I did. And one of the one of the main things I learned was—because people ask me this all the time, what did you take away from EPA?—and the answer is that I love the TCEQ. [laughter] And I say that as a joke but I do mean it and I love working for the state as opposed to federal government. It’s a different animal. I mean, it’s just, I could probably talk all day about that. If you want me to I can, but I won’t.”
Texas is Big
Lindley explained how Texas industries benefit from having a state-based regulator as opposed to a federal level regular, such as the EPA.
“Texas is big and we deal with a lot,” she said. “One thing I always tell people is that I consider myself very fortunate to be a Texan and, not to sound too cheesy when I say that, but what I mean is there’s a lot of states—and I’m talking even in [EPA] Region Six [where Texas resides] there are states that don’t have as sophisticated a natural resource agency as we have. To use New Mexico as the example… I know you [PBPA members] do a lot of work in New Mexico. In New Mexico, if you want to go get a permit to discharge wastewater, their state regulatory authority isn’t sophisticated enough. They don’t have the staff to do it. So they don’t. EPA issues those permits in the state of New Mexico. Well, I would say it’s lucky for you, if you need a permit like that, that you can come to the TCEQ, and you don’t have to go to the EPA.
“It’s just that we are big, we are large. We have amazing capabilities when it comes to monitoring the air, to testing the water. A lot of states just don’t have those resources and we do. And so consider yourselves very lucky to live in a state that can take care of you.”
Sunset Happens
[TCEQ is coming up for a Sunset determination, and she devoted a few minutes to explaining the significance of that. She began by reading the following verbiage that she said came direct from the Sunset Commission’s website:]
“The Sunset process shines a light on state agencies and programs to see if they are still relevant in a changing world. If the answer is yes, Sunset recommends improvements to make them more effective and efficient. If the answer is no, Sunset recommends abolishing the agency or transferring its functions to another agency with related functions.”
“Our Sunset process is really keeping us busy.” On March 17, Lindley explained to the PBPA membership how TCEQ works and what issues they deal with today.
[That, then, is the issue, as it is, periodically, for other Texas agencies, such as the Railroad Commission. Lindley continued:]
“The Sunset Commission is made up of a number of elected officials. There’s a Sunset agency that has staff that do these reports on different state agencies. They present their report to the Commission and then the Commission—[made up of some of] your state senators, your state representatives—vote on this report that this Sunset advisory commission has put together. TCEQ is under sunset right now. What that means is we’re basically being audited top to bottom. I use the word ‘audited’ because everyone knows what an audit is and you can relate to how painful those are. This wouldn’t be an audit of your accounting program or an audit of one little slice of your company. It would be an audit of your entire company all at once.
“They do this every 10 years, roughly. They look at what you have you done in the past 10 years. What are you supposed to be doing? They write it all down in the report. They make recommendations and then that gets voted on. That vote will happen for us in October. Then come next [Legislative] session, that report will be put into a piece of legislation that will hopefully be voted on by members. And the TCEQ will continue to exist [if] we are not abolished. I think for us to be abolished would be bad for us in the State of Texas. It would be bad if we were to go away, because then who would be the regulatory authority? We would all go back to EPA. No one wants that. [Laughter.] But that group [Sunset] will make a lot of recommendations and those will all be public.”
[The report will come out May 26, Lindley said.]
“It’s really keeping us busy. Again, I could probably talk all through lunch about the Sunset process. PBPA, I know, will be supportive and will be helpful and probably has been already. Once that report is public and we all get to see it, then we’ll all see what they’re saying about us and the ways we need to improve. But it’s a very labor intense process. We did our self evaluation report last summer. We provided the Sunset Advisory Commission with 17 different recommendations that we thought we might need either to improve on or just raise awareness of.
Water Rights
“I won’t go through all 17 of those issues, but one of the main ones we talked a lot about, which I think actually was at a water conference last week… This one’s just really fresh on the brain, but it’s a very interesting topic I think. It’s in regards to water rights. I don’t know how much y’all talk about water rights. A few guys shaking their heads. It’s a pretty hot topic for a lot of people. What we said… Well, let me back up. In 2011, remember that God-awful drought, almost took all of us out? It was bad times. Along the Brazos River basin, a senior call was made. I don’t want to get too far into the weeds on this, but a senior call is someone who has a senior water right. They happened to be Dow, the industrial company Dow. They called and said, ‘Hey, we’re not getting all the water we should be getting.’ Well, they have the most senior water right on the basin. That meant all the junior water rights had to cough up, basically, their water so that the senior could get their call.
“Because that’s how water rights work. Priority… Long story short, TCEQ oversees the issuing of water rights permits and how their handled and that kind of thing. We made the decision at the time to not make some of those junior water rights release all the water when they should have. Those people to whom we said, ‘You don’t have to do that,’ were cities. I think it was just cities, really, at that time. So we basically said, for example, and I don’t know if this is one of the cities, but Waco, Texas, ‘We’re not going to limit the amount of water you can take in because we think if we limited you, that could be a health and safety issue. You need water for your hospitals. You need water for power generation.’ It was municipalities and power generators we didn’t cut off, basically. The farmers got very, very mad. That’s okay. That’s their right. Because in the state of Texas, while you can get a water rights permit, at the end of the day, the most senior water right is for ag use. So long story short, farm bureau sued the TCEQ and we lost. We lost in court. There is now legal precedent, case law, saying the senior water rights call, you can never, ever, even if it’s for protection of human health, to make sure municipalities or power generators can generate power, you can’t cut a farmer off.
“I don’t have the solution to that problem because, obviously, ag is huge for this state and we need farmers to have water to grow our crops and to feed their cattle and do all that kind of stuff. But they put us in a real hard spot of saying, ‘Sorry, city.’ Anyway, you can think through that in your head. It’s kind of tough. We raised that as an issue in our report and said, ‘Hey, it’s just something that you should look at because it’s going to happen again. Another drought like that, hopefully no time soon, but it’s going to happen and the state needs to figure out what are we going to do if and when that happens again.’ Things like that are what we raised in the report so that the legislature could decide if they want look into that issue or not.’
TCEQ’s Challenges Are Common to Other Employers
“We talked in our report about how it’s really hard to retain employees,” Lindley said. “You hear that from every state agency, especially out here in the Permian Basin. Our goal is always compliance. That’s what we want. We want people in compliance. If we have to go to enforcement, we will, but we like compliance first and foremost. Well, in order for us to have that consistency for you all to always know what it means to be in compliance, we need our workers and we need them to not leave. We need to have not as high turnover. We raised that as an issue—that it’s hard to help with the issue of compliance and other things in the regulatory world when you have such high turnover and when the cost of living increases.
“There are the things we raised like, should public notices, when you get a permit from us, can you post them online or does it have to be in a public location for the public to get to? The pandemic taught us a lot. Now we can do a whole lot of things virtually. Do we need to update our practices? Is that helpful for people to look it up electronically? It saves money. Maybe that’s a good thing. But anyway, things like that, we raised a number of things like that in our report.
“That is by and large what the agency does… Let me say this. What I am mostly focused on probably for the next year, year and a half, is making sure the agency gets through the Sunset process, making sure when our bill is up, before it gets turned into legislation, that all the amendments that will get tacked on are good ones. Because everyone, everyone will have amendments. PBPA might have amendments. Just let me know what it is. That’s always my ask. If you want to slap something on the bill, you have every right to. Just let me know what it is. We are… waiting anxiously to see what’s being put on that report, as are whole lot of people. Other things going on at the agency that I’ll clue you in on real quick.We have been working, our office of compliance and enforcement—that’s the bulk of the people at our Region 7 office here in town, who, hopefully, y’all know them.
“Well, maybe ‘hopefully’ is not the right word [laughter.]… but… you know what I’m saying] and I hope you have a good working relationship with them. They have been working really, really hard. I have to commend them on eliminating the backlog of investigations that they’ve had on their plate. The pandemic offered them that opportunity. We were going out into the field less because there were a lot of entities that wouldn’t even let us go onto the property. A lot of corporations said, ‘Nope. No one that’s not company related can be on the property.’ We were able to clear out a whole lot of investigative paperwork, backlog stuff, and getting that taken care of is now allowing work on more pertinent issues. That’s been wonderful. Silver lining: with the past few years that we’ve gotten that backlog taken care of, currently right now, our office of air and our office of legal services are trying to find different solutions—I’ll use that word—to emission events that aren’t necessarily caused by a violation.
“Emissions events happen. It’s not necessarily because you’re doing anything wrong. We’re just trying to work on that and work on trying to find solutions. They are going to do a presentation at our upcoming trade fair. I’ll do a quick plug for that. Well, we’ve not done it for the past two years, I guess. Or three. Every year in May, we have our trade fair, and if you’ve never been, consider this your formal invitation to join us. It’s in May in Austin. It’s actually a fun time to be there. But we do have about a hundred courses that are offered. If you’re PG, you get credits. If you’re PE, you get credits. It is worthwhile. We cover… Waste permitting, water permitting, oil and gas. There’s a whole oil and gas track that we offer those two days. Industrial waste, solid waste, compliance, and enforcement remediation.
“Everything we do is covered in a two-day trade fair. The first time I ever went to it as a staffer, I couldn’t believe how big it was. If you’ve been to Austin, our conference center—well, it’s not Houston’s, but it’s pretty big. We take over the whole building. There are thousands of people that come in and go to it. I would argue it’s pretty worthwhile. Because we’re the state, we’re not charging an arm and a leg. It’s a pretty cheap conference.
“Going back to a few things that are going on in our office of compliance and enforcement. I don’t know how many people are familiar with the term ‘affirmative defense,’ or if you’ve ever claimed affirmative defense with our agency. If you have, that’s fine. I encourage people to look at the affirmative defense option if you have had a violation of your permits. But we are taking a second look at how the affirmative defense process works. It’s likely, just heads up that if you ever do claim affirmative defense moving forward, we will probably follow up your claim with a questionnaire. That might be new to you. Other regions have had it and used it for a while, but we’re trying to make it consistent across all the regions. So if you’ve ever claimed affirmative defense and then you claim it again, you might think, ‘This process is different. What’s changed?’ Just know that it has changed. We’re asking more questions because we want to make sure that all the regions are doing it the same way so it’s consistent across the state. If you have no idea what affirmative defense is, then that’s okay, because it’s an enforcement issue.
“Let me rattle off some numbers real quick…”
And Some Good News
“When we’re talking about ’emissions events,’ I was really happy to see these numbers [that she was about to share]. This is specifically for TCEQ’s Region Seven, which is mostly Permian Basin. Our Midland regional office is, by and large, [representative of] the bulk of the Permian Basin. In fiscal whole year 2019—we’re the state, so we do everything by fiscal whole year—we had a record high of 3,688 emissions events reported. Those are all self reported. In fiscal year 2020, there were 2,908. In fiscal year ’21, there were 2,152.
“And in fiscal [not calendar] year ’22, which we still haven’t closed out the books on that one, [we are sitting at] 789. So… do we want to see 700 mission events? No, but that’s a drastic decrease. So, kudos to you! That shows you are doing your part to help reduce those numbers. Thank you for working with us. It does matter. I will tell you all, you might not look at those emission events [yourselves], but there are a lot of groups, specifically NGOs [non-governmental organizations], that are constantly looking at those numbers and are constantly examining them. Thanks for your hard work in helping bringing those numbers down. That’s a great thing.
“So I just want to say that. I’ll briefly mention CO2 injections. I know there’s some people interested in that topic. The bill that passed last session transferred CO2 injection authority, some of it from TCEQ to the Railroad Commission.
“Just so y’all know, we are currently working with the Railroad Commission on updating our MOU to reflect those changes that were passed last session. And then Railroad will have to submit their package to EPA and try to get authority to do it from them. Y’all might know more about this than I do. I know Louisiana’s waiting on their approval. I think Oklahoma might be a little ahead of Texas as well, which I argue isn’t necessarily a bad thing, because you can learn from the mistakes of others. I will mention that Senator Cassidy from Louisiana, if y’all are aware, has put a hold on all the EPA area administrators. I’m sorry, not area administrators. They’re called AA’s. They’re the higher ups that each division EPA headquarters in DC [has]. But he’s put a hold on all those nominees because they need to have Senate confirmation. That’s due to Region Six’s hold up of Louisiana’s request to get that CO2 injection authority.
“I’ll talk briefly about water. That’s all little bit of a good segue because we recently had go seek authority from EPA–they program-delegated to us. Prior to January of 2021, so a year ago, oil and gas entities were required to get, if you wanted to discharge wastewater from oil and gas activities, were required to get a Railroad Commission permit and also an EPA permit. Legislators changed that up, passed a bill in the session before that. So now that program transferred from Railroad to us. Well, I’ll talk about that more in a second. Then we wake up, federal authority delegated to us. Now, if you do want one of those permits, you come to the TCEQ for it and you don’t have to go to the federal government. It’s just us. I will say I had the good fortune, I guess, of leading that for TCEQ. I think that was because I had just worked at EPA and so I knew a few people in Region Six. Region Six at that time was an outstanding partner. Kim McQueen was the regional administrator. Before his term was over in January of last year, he was bound and determined to make sure Texas got that delegated authority. We worked, I would argue, the best we ever worked with EPA for anything, at least in my time, and got that delegated authority. With that, let me just say this one little thing. Railroad does still have some authority over the disposal and the reuse of oil and gas waste water. If you want to inject it, if you want to put it into evaporation ponds or land apply it, you’ll still go to Railroad. However, and there’s more and more talk about this, so that’s why I bring it up, if you do want to discharge into water of the state, your produced water, your hydrostatic test water, you’re not exempt. Storm water, gas plant fluid. There’s a whole long list of things. We are now the main authority for that.
“Anyway, we haven’t gotten crazy busy with that, but we worked very, very hard, very, very quick to get that delegation done in a very, very short amount of time. I think probably a decent amount of y’all are familiar with the Texas Produced Water Consortium that’s housed at Texas Tech. Yeah. See a few of you guys nodding. We’re involved with that as well. Obviously, I think it sounds really cool. Sounds really interesting. We’ll see what comes out of that. Let me now jump to Air.
Something Happened
“So one day a tragic accident happened. An oil and gas worker and an attorney were killed in a car accident. They both got up to heaven at the same time. And St. Peter greeted them and he said, ‘Come with me, gentlemen.’ We will say ‘gentlemen’ for the sake of the story. ‘Get into my holy convertible. I’m going to take you to your homes where you’ll spend eternity.’ So they start driving and they drive and they take a right and they turn on this road that’s just paved in silver, just stunning. Keep driving, they get onto a road that’s paved with gold and just gorgeous. Keep driving and they turn onto a road that’s paved in platinum and it’s just blinding, it’s so beautiful. And then they take a last turn. They turn to a road paved with diamonds and it is as gorgeous as you can imagine, just sparkling, amazing. Pull up to this mansion that is breathtaking. Peter says, ‘Lawyer, get on out. This is your house. If you need anything for the rest of eternity, please let me know.’
“So then the oil field worker and Peter get back in the car. They start driving and they trace the same path back. So they take the road covered in diamonds, then get on the platinum road, then get on the gold road, silver road. Then they get on a regular asphalt road and they keep driving. And then they turn on a dirt road and they keep driving. And then they get into a road that’s like, at best, potholes. And they pull up to this shack of a house and Peter says, ‘Oil field worker, here’s your home. Please enjoy your time in eternity. Let me know if you need anything.’ The worker said said, ‘Whoa, whoa, what is this? No offense, but I worked hard all my life. I was faithful to my wife and family. I took care of the yard as best as I could. Why does the attorney get the beautiful place?’ And Peter said, ‘Oh, well, we’ve never had one of them before so we’re really trying to impress them.’ It’s a joke It’s just a joke because of how many attorneys are in the room.
“But anyway, so that’s my lead-in to topics of Air, because everything we talk about is going to be litigated and more than likely for years to come. So as y’all know, probably y’all can probably speak to it more than I can at the moment, at least. Because I know you’re very, very familiar with what’s happening in New Mexico. And the recent petition that EPA Region 6 received concerning those two air monitors of New Mexico. Well, and Hobbs and Carlsbad, that have allegedly been showing high concentrations of ozone. And the discussions out there that those are being caused by the energy sector. And that a lot of it’s coming from the Permian Basin, the Texas side. And we know that EPA is allegedly looking at different options to resolve the issue. We are watching that closely because… Not to get into super boring Air discussion, but if they were to ever make a suggestion of changing the attainment status in the Permian Basin, that would have huge implications for your industry.
“Some heads are shaking. Talk to any of your friends in Houston, any of your cohorts that are Houston, bring up at the word ‘attainment’ and you’ll get an earful. It is… we could go worst case scenario and I could scare the pants off of you of what all that could mean for the state. But I won’t. Just know that we’re monitoring it. We’re watching. I’ll just stop there.”
The Methane Rule
“I’ll mention the methane rule, because obviously that’s a big one. It’s happening right now. We, along with Railroad, submitted joint comments on their draft rule making… The timeline has always been that they are going to allegedly release the rule, excuse me, in April. I don’t know what’s going to happen with that. I mean, there’s a lot going on in the world right now. You know, Julie and I were talking about this earlier. Does EPA do that in April? I don’t know. We’ll see.
“And the whole reason I told my story about attorneys is because we have some very smart attorneys that are on top of that issue. Our governor has made it very clear and been very vocal about… whether it’s TCEQ, whether it’s Railroad, whoever it is, the State of Texas will be fighting whatever kind of regulations are put on the fossil fuel industry by the federal government. So just know that whatever comes out, we will be very engaged on. We have direction from our governor on what we might need to do there. And so we’re watching it very, very closely. Some of the high points of our comments, just so y’all know. And again, these were in conjunction with Railroad. Are that we think EPA’s authority to issue the new source performance standards for methane under certain provisions of the Federal Clean Act are not resolved due to a lot of pending lawsuits that are out there.
“So we don’t think they need to be doing this until those pending lawsuits are done. We also, the TCEQ, does not have the legal authority or framework required to implement the methane rule or to regulate minor sources from methane’s emissions. So we, the TCEQ, in Texas will need sufficient time to implement whatever they propose. We’d also like public input on what that might look like. So we’ve said in our comments, if you’re going to do this, you got to give us time to do it. And you’ve got to give us time to hear from the public on what that needs to look like.
“We claim that it’s an unfunded mandate and if EPA’s going to do it, they should provide the states additional resources. And we believe that EPA has vastly underestimated the overall number of affected facilities and particularly the potential impact on small businesses. And so all that was raised in our comments. EPA has been on a big kick since last year,under the new administration, about environmental justice. And I know you all probably hear that term a lot. It’s not defined anywhere, but they use it a whole, whole lot. And the Region 6 administrator’s very passionate about that issue. And so that will somehow be worked into a rule making. I don’t know what it’ll look like, but it will have to be in there. And that’s part of this administration’s, one of their big talking points… I think that’s all I can mention on that thing. We could talk a lot about that.
“Two other rules I’ll mention really quick. And then I really will be done. They are just happening at the agency that one day could affect something you’re doing. We have a compliance history rule making that’s been going on for a couple months. The agency has proposed adding a new subsection to our compliance history rule that provides our executive director with the ability to reclassify a science compliance history, their classification, if they are involved in an emergency event. And so an example would be something that’s happened over the past couple years, we’ve seen more than we would like is a big, huge explosion, right? At a refinery or something like that. We’re talking something major where different economies might be affected, right?
“I mean, if you have a refinery explosion, there’s a lot of examples I could use, unfortunately, but one of the big ones would be the [unaudible] Tip explosion that happened in March or April of ’19, I guess it was. That was one that shut down the Houston Ship Channel for a couple days. That’s huge. And the Houston Ship Channel shutting down, that doesn’t just affect a few industries. But those industries right there on the ship channel—it affects everyone. So this is a way to try and deal with those highly improbable big events. What it’s basically was going to do, if you have one of those big events, it would give the executive [inaudible] authorities say, ‘Okay, this site is now going to be reclassified as “under review.”’ That’s the term we use.”
Review Periods
“And there will be a review period that you are under review and you could potentially have your compliance rating moved to either suspended, depending on what the investigation were to reveal, or a different level. We have different levels of classification. Anyway, hopefully you don’t ever to know any more about that, but it could be a big deal. If you have a big event that causes a lot of problems, yeah. That would be a change. The public communication period has recently ended on that. And so the rule will come up before the commissioners for adoption in June. That’s the timing of that right now. We also have a public participation rule making that I’ll mention real quick. It’s very, this week got some media attention. I think it was the Texas Tribune.
“We have adopted several rules relating to public participation. And one of the provisions is going to require entities to do a one page summary providing an overview of a project. And right now we’re working on the template of what that one page summary might look like. So what we’re telling entities is, when you come in for a permit, yes, you’ll have to go through all the notice requirements you’ve always gone through, but you’re also going to do this one page simple language summary so that a member of the public can read it and say, ‘Oh, okay, that’s what this is.’
“There’s a long history about how this rule making came about, but just know that we’re working on that. And the very last thing I’ll mention is that we are back in the office. We fully started back up March 1st. We have adopted a hybrid workforce and so our employees, by and large the bulk of our employees, there are some exceptions, are in the office two days, or teleworking two days. And then the fifth day is, depending on their job, they might be in the field. They might be in the office. They might be teleworking. So that’s what’s happening at the agency. I don’t know what time it is. Do you want to wrap it up? Do you want to take a question or two? Anyone have a question? I’ll be around for a few minutes.”
END