INGAA & AGA Response to Advance Notice of Proposed Rulemaking to Revise Regulations Concerning the National Environmental Policy Act

The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the Council on Environmental Quality’s (“CEQ”) request for comment on potential revisions to its regulations concerning the National Environmental Policy Act (“NEPA”).

Interstate natural gas pipeline projects are often subject to broad review by multiple federal agencies, which must jointly fulfill their individual obligations under NEPA. Ensuring coordinated, streamlined NEPA review among multiple agencies is essential to the timely development of infrastructure required to meet the public need for natural gas.

In the forty years since CEQ promulgated its NEPA regulations in 1978, there have been significant changes in the way agencies review projects and how they develop, share, and analyze information in support of their decisions. For example, technological advances since 1978 permit gathering and analyzing information in greater amounts and detail than before, which can both more efficiently inform agency decision-making, but also may lead agencies to more comprehensive and detailed reviews than are actually necessary for their decision-making. Greater focus on the purposes of NEPA, and more emphasis on coordination and efficiency among federal agencies, are needed if NEPA reviews are not to overrun their mandate.

INGAA and AGA support CEQ’s interest in making durable revisions to its NEPA regulations. INGAA and AGA appreciate the opportunity at this early stage of CEQ’s rulemaking process to provide comments on key principles of revision and additional clarity around issues that are frequently litigated. As the rulemaking process unfolds, INGAA and AGA look forward to providing additional comments.