Due to the linear nature of interstate natural gas pipelines, INGAA’s members have extensive experience with and interest in the process for obtaining Clean Water Act (“CWA”) permits and, in particular, Section 404 permits. While the Draft Guidance is focused on the substantive issue of defining “waters of the United States” subject to CWA jurisdiction, it has the potential to negatively impact Section 404 permitting both substantively and procedurally.
Substantively, the Draft Guidance significantly and improperly expands EPA’s and the Corps’ CWA jurisdiction with a cumbersome and difficult-to-implement definition that will increase the costs, timing, and administrative burden of Section 404 permitting with little conservation benefit.
Related
Natural Gas & Power Industries’ Reliability Alliance:
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
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
