CZMA INGAA Comments on NOAA Proposal 8-25-03

Pursuant to the proposed rule issued in the referenced proceeding on June 11, 2003, 1 the Interstate Natural Gas Association of America (INGAA) submits the following comments on the National Oceanic and Atmospheric Administration’s (NOAA) proposal to revise the Federal Consistency regulations promulgated under the Coastal Zone Management Act of 1972 (CZMA).

INGAA submits that the proposed rule is legally deficient due to NOAA’s mischaracterization of its legal authority under the CZMA as it applies to interstate natural gas pipeline projects that have been authorized by the FERC pursuant to the NGA.

INGAA appreciates NOAA’s proposals to improve its Consistency Regulations by specifying deadlines for action by the states and by NOAA itself. Still, INGAA suggests that, at least within the context of interstate pipeline projects that are subject to the FERC certificate process under the NGA, even more expedited regulations can be adopted.