Last month, ACRA submitted comments to the US Army Corps of Engineers regarding their proposal to reissue and modify nationwide permits (NWPs). The notice was initially published in the Federal Register on September 15 regarding the reissuance of 52 NWPs and 5 new NWPs. ACRA's comments focused on the need for pre-construction notifications, thresholds for oil and natural gas pipeline activities, and tribal rights in the process. ACRA's full comments can be viewed by members here.

Additionally, ACRA was invited to comment further on the Forest Service National Phasing Programmatic Agreement (PA) under section 106 of the National Historic Preservation Act. The original draft from the Forest Service was issued in the winter of 2019/2020, and ACRA provided comments as a part of the Coalition for American Heritage. ACRA's comments on the latest draft focused on:

ACRA members can read the full comments here.