On October 9, 2014, as part of an industry coalition, INGAA filed comments in response to the two proposed rules and a policy statement jointly issued by the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. The proposals would significantly revise the critical habitat review process under the Endangered Species Act. The Services’ proposals are based on speculative information and will unjustifiably expand the Services’ authority to designate critical habitat. For example, the Services could designate land as critical habitat even if it is currently unoccupied by the species and contains none of the physical or biological features required by the species. Under the proposal, designations of critical habitat could rest on estimates of future species needs and projections of local climate change impacts.
INGAA filed the comments with American Petroleum Institute, Association of Oil Pipe Lines, International Association of Geophysical Contractors, Utility Air Regulatory Group, and Utility Water Act Group.
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