Regulatory Submissions

On March 28, 2025, APGA joined the U.S. Chamber of Commerce and 27 other trade associations on joint comments in response to the Council on Environmental Quality’s (CEQ) interim final rule titled Removal of National Environmental Policy Act [NEPA] Implementing Regulations. Click the link below to read the comments.

The comments welcomed the administration’s efforts to streamline environmental reviews under NEPA, as outlined in President Trump’s Executive Order, Unleashing American Energy, and supported the goals of NEPA to inform federal decision-making and the public’s understanding of the potential environmental impacts of federal actions. The interim final rule recognizes, and the comments agree, that CEQ has the authority to take on a strong advisory role to ensure efficient implementation of NEPA and promote uniform analysis among agencies. However, the comments ask CEQ to take the following steps when finalizing their rule:

• CEQ should guide agencies to adopt NEPA procedures that are consistent with the text of the statute and unambiguously reflect NEPA’s procedural role.
• CEQ should guide agencies to expand available Categorical Exclusions and rely on programmatic review options and tiering to reduce unnecessary red tape for review of proposed actions when appropriate.
• CEQ should guide agencies to adopt requirements for a narrowly tailored, clearly defined purpose and need statement and alternatives analysis that reflect the applicant’s goals and the agency’s statutory authority.
• CEQ should encourage agencies to ensure they have adequate staffing to undertake NEPA reviews.

While many projects undertaken by APGA members do not require NEPA reviews, projects funded by the Pipeline and Hazardous Materials Safety Administration (PHMSA) Natural Gas Distribution Infrastructure Safety & Modernization (NGDISM) grants do. The comments submitted to CEQ emphasize the importance of Categorical Exclusions, programmatic reviews, and tiering – all of which are tools that PHMSA has successfully used in the NGDISM program. Furthermore, NEPA reviews are required for other activities important to APGA members, such as the construction of interstate natural gas transmission pipelines and the Clean Water Act’s Nationwide Permit Program. Efficient NEPA reviews for these activities are also beneficial to public gas utilities.