The Interstate Natural Gas Association of America (INGAA) is a primary liaison organization representing the Natural Gas Industry and, as such is closely involved in support activities relating to the Federal Energy Regulatory Commission (FERC) National Environmental Policy Act (NEPA) review/approval process. Any project that constitutes a "major federal action is required to undertake appropriate and often exhaustive studies under NEPA in order to determine and mitigate project environmental impacts. The FERC is charged with critical review and subsequent approval of all NEPA studies relating to natural gas industry installations. This review process has been in place for a number of years and has therefore been tried and tested on a multitude of various size projects whose implementation timetable has very often been severely impacted by FERC NEPA review policies and procedures. These delays have translated into considerable additional company project expense as well as higher costs to natural gas users.
While the FERC NEPA review process ultimately results in specific project approvaVdisapproval determinations, the gyrations and delays that project applicants are subjected to can only be described as frustrating, expensive, and for the most part unnecessary. Since the early 1980s, the FERC has steadily increased the complexity of the review process with corresponding increases in staff positions and control. This has resulted in a double layering effect wherein the FERC environmental staff are often involved in reworking the in-field approval determinations made by NEPA required state/federal participants such as the U.S. Fish & Wildlife Service and the State Historic Presexvation Officers. Natural gas industry projects are difficult enough in themselves to implement, but when one adds the stumbling blocks presented by a heightened and often unnecessary level of FERC control, the results can be catastrophic.
With the above in mind, Environmental Management & Engineering, Inc. (EMEAttachment 1) was asked by the INGAA Foundation to undertake a study aimed at a critical review of the FERC NEPA review process in order to isolatdidentify problematic areas that could be changed or eliminated in order to speed up the project reviewlapproval process.
