We embrace our responsibility to protect the planet, build inclusive communities and grow a sustainable, strong economy that is powered by a diverse energy and manufacturing portfolio, unmatched by any other nation in the world. Building modern, resilient infrastructure through innovation and responsible development has long been a priority. We have established a strong record in environmental protection and economic development which is why we, the undersigned organizations, submit the following comments to the U.S. Army Corps of Engineers (“Corps”) in support of the proposed rule to “Reissue and Modify Nationwide Permits.”1
Our members have a substantial and direct interest in the outcome of this rulemaking and are calling for smart regulations that protect the environment, create jobs, drive innovation and ensure a better quality of life for everyone. To accomplish these goals, regulations governing our nation’s land, water and infrastructure must be designed with the utmost care to ensure that regulations are effective in achieving their desired objectives, while simultaneously avoiding unnecessary environmental, social and economic impacts. A strong nationwide permitting program will continue to ensure that our nation can prosper and grow sustainably and responsibly.
Nationwide Permits Build Inclusive Communities
For too long, our nation has relied on transportation, communication, water and energy infrastructure inherited from previous generations — weakening our economy, threatening our communities and putting the safety of our families at risk. However, great things can happen when concerned citizens, businesses and governments work together with shared purpose, goals and outcomes. Federal policies that balance environmental protection and commercial feasibility empower us to deliver sustainable solutions for a prosperous tomorrow.
The Nationwide Permitting program is an essential tool, facilitating the development of critical, resilient infrastructure that helps communities thrive. Permits issued by the Corps play an important role authorizing infrastructure projects that build more inclusive communities and deliver opportunities for a better life. Next-generation transportation, water and energy infrastructure will provide greater mobility and connectivity, improve access to job opportunities and diversify options for lifeline infrastructure, such as food, healthcare, housing, internet and electricity. When we reduce transportation, water and energy costs through more advanced and more reliable services, consumers benefit from lower prices of household products. Through continued investment and innovation, modernizing our nation’s critical infrastructure is key to creating a brighter, more sustainable future for everyone. To continue these benefits, we support the swift reissuance of the Corps’ nationwide permit program.
Nationwide Permits Safeguard Our Water Resources and Foster Sustainability
The nationwide permit program plays a critical role in empowering the deployment of the clean energy our nation needs. The program facilitates continued investment in clean infrastructure and encourages environmentally and economically sustainable modern energy options to safeguard our people and our planet.
The program allows the Corps and project applicants to streamline the permitting process for projects known to have only minimal impact on water resources. Nationwide permits provide general approval, with minimal delay and paperwork, for projects that are similar in nature, have minimal environmental impact and can meet specific conditions and restrictions that guarantee strong protections for aquatic ecosystems. This process enables project applicants to dedicate resources appropriately by making sound, long-term investments while meeting regulatory requirements.
Nationwide Permits Promote Economic Growth and Global Competitiveness
The nationwide permit program works. Data from the Corps show that, in 2018, the average time that it took to process a standard individual permit was 264 days.2 In contrast, average nationwide permit processing time was 45 days.3 The difference is stark and provides concomitant benefits. Project proponents are incentivized to tailor their projects to minimize environmental impacts so that they quality for nationwide permit usage. This ensures that the Corps can focus tax-payer resources on more lengthy and complicated projects that warrant individual permit analysis. This enables project development that accelerates economic growth and secures America’s role as a top global competitor.
The nationwide permit program leads to increased investments in infrastructure, which in turn, creates jobs and sets off a positive ripple effect across a diverse workforce. For example, “a $1 trillion infrastructure investment could create 11 million jobs. Approximately 10 percent of infrastructure jobs would be in manufacturing with specific needs for skilled workers in fields such as information technology and data science.”4 Manufacturing and construction jobs have a powerful multiplier effect on our economy; for every $1.00 spent in manufacturing, the economy grows by $2.73.5 Additionally, for every worker hired in the manufacturing and construction industries, another 3.74 workers are added to the larger economy.6
To ensure that our domestic prosperity and productivity continue to grow, it is time for the U.S. to take the lead on the global stage. China’s infrastructure investment is almost double the size of the infrastructure spending in the U.S., and India’s infrastructure investments are growing at triple the rate of the infrastructure outlays of the U.S., Canada and Mexico combined. By increasing our investment into infrastructure, we reinforce our commitment to address global climate change while preserving global competitiveness. The Corps’ nationwide permit program will help accomplish these objectives while facilitating speedy delivery of infrastructure investments that will better serve Americans, improve commerce and communication, bolster national security and pave the way for the success of the next generation.
The choice between environmental protection and a strong economy is not an either/or proposition. Americans deserve both. Understanding this and taking the necessary steps to protect this balance creates jobs, spurs domestic investment and ensures a healthier planet for all of us. The nationwide permit program is the gateway to building sustainable, prosperous and inclusive communities.