To reduce the regulatory burdens on interstate pipeline and other infrastructure projects created by the uncertainties in the Clean Water Act (CWA) Section 401 certification process, INGAA recommends that EPA amend its regulations implementing CWA Section 401 to ensure that states comply with the statutory requirement to act on water quality certification requests “within a reasonable period of time (which shall not exceed one year).” Amendments are needed to address states’ actions that result in delays when acting on requests for water quality certification beyond “a reasonable period of time (which shall not exceed one year).” These clarifications would effectively enable federally-approved natural gas infrastructure projects to proceed on schedules established by the lead federal agencies such as Federal Energy Regulatory Commission (“FERC”) or US Army Corp of Engineers (“USACE”).
Download the full comments here.
Related
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
