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Alerts, Agency Documents
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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 Statement of Issues filed for Subpart W Court Case AGA v. EPA (March 2, 2011) 

On March 2, 2011 AGA filed a non-binding Statement of Issues to be raised in the court case AGA v. EPA.  AGA challenges several provision in EPA’s mandatory greenhouse gas reporting rule for natural gas systems, because the rule is so vague and confusing that our members cannot determine what the rule requires them to do.  In addition, many of the confusing terms and requirements are undefined and appeared for the first time in the final rule, so AGA had no opportunity to comment on them, as required by law.  We challenge these provisions on the grounds that they are vague, arbitrary and capricious or otherwise not in accordance with law.  Among the list of issues, AGA challenges the following undefined terms: "custody transfer city gate station," "non custody transfer city gate station" and "facility with respect to natural gas distribution".  AGA also lists challenges to leak measurement requirements, emissions quantification, and requirements for natural gas distribution, underground storage and LNG facilities.    See AGA’s administrative Petition for Reconsideration, filed with EPA on March 2, 2011, for a more complete explanation of the problems we have identified in the “Subpart W” greenhouse gas reporting rule, and how we want EPA to review the rule to fix these problems.  If EPA agrees to make these changes, we should be able to resolve the litigation and withdraw our court challenge.

The Statement of Issues is posted under Environmental Comments and can be accessed by clicking here.


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