On Dec. 10, AGA filed the attached comments with the Government Accountability Office’s Natural Resources division, regarding an opportunity to improve environmental consultations and permitting required for natural gas pipeline and infrastructure projects under the national Endangered Species Act (“ESA”). The purpose of these comments is to provide insight into the differences in timelines, processes and outcomes for natural gas projects that have the benefit of a participating federal “lead” agency (an “action agency”) that initiates the environmental consultation with resources agencies like the U.S. Fish and Wildlife Service (USFWS) because it must issue its own federal permit, and those projects that do not have an action agency to lead environmental consultations.
In addition to the discussion of ESA reviews, our letter also discusses timeline management issues faced in other environmental and natural resource consultations, where an action agency cannot effectively enforce review timelines with other agencies or stakeholders participating in historical and cultural resource reviews required for federal permits. We have included documentation and regulatory language that explains the relevant environmental consultation processes for both intrastate and interstate natural gas pipeline projects.
AGA's Comments Regarding Federal Agency Leadership of Environmental Consultations