INGAA appreciates the Commission’s initiative to update its Guidance Manual for Environmental Report Preparation. Since it was published in 2002, there have been numerous developments both generally under the National Environmental Policy Act (NEPA) and the Council on Environmental Quality’s (CEQ’s) regulations thereunder, and, specifically, in the individual Commission certificate proceedings applying NEPA, the CEQ’s regulations and the Commission’s own regulations under NEPA. With the large increase in the number of comments submitted by stakeholders in certificate proceedings, the types and amount of information required by FERC staff prior to issuing the environmental documents has grown significantly, as has the average duration of the environmental review.
INGAA agrees with the Commission’s goal to provide industry with helpful guidance on preparing resource reports so applicants can increase the overall quality and consistency of data analyses. This, in turn, could help minimize or avoid delays in processing of certificate applications and lessen the need for extensive data requests.
Still, INGAA has identified a number of concerns in the Draft Guidance Manual – both in general and specifically related to individual resource reports – that it would like to highlight. INGAA requests that FERC staff finalize its Guidance Manual to reflect INGAA’s proposed revisions, recommendations and clarifications.
Read INGAA's comments in their entirety by clicking on the PDF above.
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