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AGA Comments on the EPA Stormwater Notice March 5, 2012
AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012)
Regulating Construction Site Stormwater Discharges with a Strong Statewide Program in Alabama (Dec. 3, 2012)
Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012)
AGA Comments on Water Resources Permitting in California for Natural Gas Projects (Dec. 7, 2012)
AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012)
Comments on EPA’s PCB Transportation Manifest Rules (Nov. 5, 2012)
Sierra Club v. Bostick – Briefs to 10th Circuit in Appeal of Order Denying Motion for Injunction (Oct. 2012)
Courts Deny Sierra Club’s Motions for Injunction (Aug. 29, 2012)
Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012)
AGA Joins Multi-Industry Letter to Senate on TSCA Legislation (Aug. 21, 2012)
AGA Comments on EPA Proposal to Amend NESHAPS for Reciprocating Internal Combustion Engines (Aug. 9, 2012)
Sierra Club v Bostick - AGA Moves to Intervene in Support of Streamlined Utility Wetlands Permit (July 30, 2012)
Court Grants AGA's Motion to Intervene in Sierra Club v. Bostick (Aug. 1, 2012)
AGA Comments on EPA GHG Subpart W Reporting Rule Technical Corrections (June 20, 2012)
AGA Comments on EPA Subpart W Greenhouse Gas Confidential Business Information & Reporting Deferral Proposed Rule (April 9, 2012)
AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)
AGA Court Challenge to GHGReporting Rule Subpart W Technical Revisions (Feb. 21, 2012)
AGA Supports SoCalGas’ Challenge to California Anti-LNG Rule (Jan. 4, 2012)
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 AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012) 

On December 3, the American Gas Association filed comments with the Government Accountability Office regarding the benefits and gaps in a permitting tool administered by the Pennsylvania’s Department of Environmental Management (PADEP) which GAO plans to feature in its upcoming report on natural gas project permitting. 

AGA’s letter explains how the tool has been helpful, based on feedback from Pennsylvania members who use the tool regularly for their project planning.  AGA also explains that the tool does not account for timing problems that utilities face when the system generates mitigation requirements and seasonal survey requirements that must be completed, sometimes months later, before PADEP begin reviewing their permit application.

As such, our letter compares this Pennsylvania tool to the IPaC planning and siting tool being developed at the U.S. Fish and Wildlife Service, and notes the substantial capacity of the IPaC program to actively manage information, timelines for different agency reviews, and preview necessary project mitigation requirements so that natural gas projects can benefit from a coordinating “home” for all their environmental reviews even when there is no federal “action agency” leading these reviews. 

 AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits



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