Published

June 17, 2020

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TO THE MEMBERS OF UNITED STATES CONGRESS:

The undersigned organizations urge you to make permit streamlining a centerpiece of any future bill to rebuild America’s infrastructure. Including provisions that modernize the Federal environmental review and permitting process to reduce delays and enhance project planning and delivery is paramount to realizing our shared goals of economic recovery and continued environmental protections.

Our organizations represent sectors that provide critical infrastructure and services for the American economy across a broad range of sectors, including agriculture, energy, forestry, manufacturing,
construction, transportation, and more. We fully support the fundamental environmental stewardship goals of the National Environmental Policy Act (NEPA); however, it is widely recognized that these review processes have become hampered by unreasonable costs and long project delays.

Since the beginning of NEPA implementation in the 1970s, the time it takes to complete environmental reviews has increased significantly, unnecessarily delaying investment and environmental stewardship. According to the Council on Environmental Quality (CEQ), the average completion time for the environmental review process is now four and a half years, with transportation project reviews taking more than six years. These long reviews delay investment in modern, efficient infrastructure and job creation, including potential reductions to congestion-related emissions, enhanced climate resiliency, and all forms of energy including solar and wind projects.

It is time to restore the original intent of NEPA review processes, which was to promptly consider relevant environmental information and arrive at an agency decision without delay. For example, CEQ’s first implementing regulation from 1978 included a number of provisions aimed at facilitating expeditious permitting decisions by “reducing delays,” setting “appropriate time limits,” and
implementing process requirements concurrently. Further, CEQ issued a memorandum in 1986 advising agencies that “under the new NEPA regulations even large complex energy projects would require only about 12 months for the completion of the entire EIS process.”

Moreover, reducing delays and uncertainties associated with infrastructure investment and related projects has the potential to support good paying jobs when the economy needs them most. The need to maintain America’s competitive edge and attract global investment is especially important given our current economic challenges. The American Society of Civil Engineers gave American infrastructure a D+ grade in their most recent report card, highlighting the need to improve and expand our infrastructure to more efficiently move people, goods, energy, and information across the country. To provide the near-term economic boost needed with any infrastructure bills and maintain America’s competitive edge, permit streamlining will be a necessary accompaniment to speed up decision-making to benefit local communities and the U.S. as a whole.

Adopting permit streamlining policies in conjunction with any infrastructure bill would reduce delays and improve the predictability of the Federal permitting process allowing businesses to plan and invest with confidence while enhancing economic productivity and environmental stewardship. This is a priority with bipartisan support, and we are committed to work with you to ensure its inclusion in forthcoming infrastructure legislation.

Sincerely,

Agricultural Retailers Association
American Coke and Coal Chemicals Institute
American Council of Engineering Companies
American Highway Users Alliance
American Public Gas Association
American Road & Transportation Builders Association
Associated Builders and Contractors
Associated Equipment Distributors
Associated General Contractors of America
Association of American Railroads
Association of Equipment Manufacturers
Association of Oil Pipe Lines
Building a Better America
Consumer Energy Alliance
Energy Equipment and Infrastructure Alliance
Federal Forest Resource Coalition
Independent Petroleum Association of America
Laborers' International Union of North America
LNG Allies, The US LNG Association
National Association of Home Builders
National Cattlemen's Beef Association
National Lime Association
National Mining Association
National Ocean Industries Association
National Rural Electric Cooperative Association
North America’s Building Trades Unions
Portland Cement Association
Public Lands Council
The Fertilizer Institute
The National Stone, Sand & Gravel Association
U.S. Chamber of Commerce