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.