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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)
Government Links
Prior to 2006

 Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012) 

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

 HCP Timelines



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