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Alerts, Agency Documents
Comments
Statement of Issues filed for Subpart W Court Case AGA v. EPA (March 2, 2011)
AGA Petition for Reconsideration of Subpart W (March 2, 2011)
AGA Subpart W Comments to EPA (June 11, 2010)
AGA Subpart W Comments to OMB (May 12, 2010)
AGA Overview and Chart of Current Leak Survey & Repair Rules (May 12, 2010)
AGA Presentation Slides for Meeting with EPA on Greenhouse Gas Subpart W Proposed Rule (May 6, 2010)
AGA Testimony on EPA Proposed Greenhouse Gas Reporting Rule for Natural Gas Facilities – Subpart W (April 19, 2010)
AGA Comments on EPA Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change (March 25, 2010)
AGA Comments Challenge Site-Based DOE Residential Water Heater Energy Efficiency Standards (Feb. 9, 2010)
AGA Comments on EPA Finding of Endangerment – Climate Change Proposal (June 23, 2009)
AGA Comments on EPA's Greenhouse Gas Reporting Rule (June 9, 2009)
EPA Response to AGA on Climate PSD Tailoring Rule (Feb. 12, 2010)
AGA Letter to EPA Administrator Jackson on PSD Tailoring Rule – Role of Natural Gas in Climate Policy (Jan. 22, 2010)
AGA Comments on EPA Greenhouse Gas PSD Tailoring Proposed Rule (Dec. 27, 2009)
AGA Comments Urging DOE to provide ARPA-E funding (Sept. 25, 2009)
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 AGA Comments on EPA Greenhouse Gas PSD Tailoring Proposed Rule (Dec. 27, 2009) 

On December 27, 2009 AGA submitted comments on EPA's Greenhouse Gas PSD Tailoring Proposed Rule.  These comments note AGA's reasons that the proposed thresholds are still significantly too low both for sources in general and for natural gas burning sources in particular.  The proposed threshold is based on a source’s “potential to emit” rather than actual emissions – making the artificial assumption that a furnace or boiler will operate constantly, 24 hours per day and 365 days per year.  Finally, AGA's comments suggest steps EPA could take to allow additional time for the agency, states and the regulated community to adapt the PSD program to cope with the challenges of greenhouse gas emissions. 

The cover letter, comments and attachments are posted under Environmental Comments and can be accessed by clicking here.

 
 

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