Dear Ms. Coulombe,
The Interstate Natural Gas Association of America (“INGAA”) respectfully submits these comments in response to the United States Army Corps of Engineers’ (the “Corps’”) request for input on existing regulations that should be repealed, replaced or modified. 82 Fed. Reg. 33,470 (July 20, 2017). Specifically, the Corps seeks public assistance in identifying existing policies and regulations that eliminate jobs or inhibit job creation; are outdated, unnecessary, or ineffective; impose costs that exceed benefits; and create a serious inconsistency or otherwise interfere with regulatory reform initiatives and policies. 82 Fed. Reg. at 33,470-71.
INGAA is a non-profit trade association whose member companies transport over 95% of the nation’s natural gas through a network of 200,000 miles of pipelines. Ensuring the safety, security, and reliability of this natural gas pipeline network is crucial to meeting the energy needs of the United States and contributes directly to the U.S. economy by powering domestic industry and providing jobs.
The siting, construction, and operation of interstate natural gas pipelines is governed by the Federal Energy Regulatory Commission (“FERC”) under the Natural Gas Act (“NGA”), 15 U.S.C. §§ 717, et seq. Where new pipelines and maintenance activities will affect waters of the United States, the Corps administers permit programs under section 404 of the Clean Water Act (“CWA”) and/or section 10 of the Rivers and Harbors Act.
INGAA believes that the Corps’ regulatory reform initiative, and the adoption of the recommendations included herein, is critical to achieving the Trump Administration’s goals of expediting environmental reviews and approvals for infrastructure projects.1 Our members have gained substantial experience with these programs, and they appreciate the Corps’ renewed effort to improve the programs’ effectiveness and efficiency so that pipeline infrastructure is not needlessly delayed or restricted while protecting the nation’s waters. To that end, INGAA provides the following comments and recommends that the Corps should:
Download the full comments here.