AGA USFS NEPA Comments 8.26.19
In comments filed August 26, 2019, AGA supported the U.S. Forest Service’s proposal to modernize and streamline its regulations implementing the National Environmental Policy Act (NEPA). These comments commend the Forest Service for recognizing the need to revamp its existing NEPA procedures and strongly support the Service’s effort to modernize its NEPA policies. AGA believes that many of the proposed modifications will improve the Forest Service’s NEPA processes, eliminate duplicative reviews, and encourage more uniform decision-making. Specifically, the addition of procedures which would allow the Service to use a previously completed NEPA analysis to satisfy NEPA requirements for an essentially similar proposed action should help reduce redundant analyses for similar projects with similar environmental impacts. Similarly, allowing materials to be incorporated by reference in NEPA documents should reduce redundancy, enable the Service to capitalize on the analyses and findings of previously completed studies, and result in more concise documents. AGA also believes that the Service’s expanded use of categorical exclusions (CE) strikes an appropriate balance between gaining efficiencies in the NEPA process while continuing to ensure that that important objectives of the NEPA statute are met. AGA’s comments also offered several recommendations intended to clarify and improve the proposed rule, particularly regarding the scope and applicability of proposed CEs. AGA member companies rely on timely, transparent federal permits and reviews to meet their construction, maintenance, and replacement goals. AGA strongly supports the Service’s efforts to improve and modernize its NEPA procedures and believes that the proposed rule strikes an appropriate balance between efficiency and environmental stewardship.