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Additional Information
USWAG AGA Comments on EPA Electronic Manifest System (June 19, 2006)
AGA's Separate Comment Letter on EPA Proposed SPCC Rule for Oil-Filled Equipment (Feb. 10, 2006)
AGA's Separate Comment Letter on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006)
AGA Comments on Corps of Engineers Chicago District’s Nov. 3, 2006 Proposed Regional Conditions for Nationwide Permit Reissuance (Nov. 27, 2006)
Joint USWAG-AGA Comments on EPA Proposed SPCC Rule for Oil-Filled Equipment (Feb. 10, 2006)
Joint USWAG-AGA Comments on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006)
USWAG Letter to EPA Requesting Opportunity to Comment on EPA PCB Site Revitalization Guidance (June 12, 2006)
USWAG-AGA June 19, 2006 Comments on EPA’s Electronic Manifest System
Senate Climate Change White Paper on Options for a Mandatory Greenhouse Gas Trading Program, with AGA Response
API Comments on Proposed Wetlands Nationwide Permits (Nov. 27, 2006)
AGA’s February 6, 2006 Comments on the U.S. House NEPA Task Force Draft Report
AGA February 8, 2006 Comments on the Draft Environmental Impact Statement (DEIS) for the Atlantic Rim Natural Gas Development Project, Notice of Availability 70 Fed. Reg. 73481
AGA Comments on the Draft Resource Management Plan and Environmental Impact Statement (DRMP/EIS) for the Upper Missouri River Breaks National Monument, MT, Notice of Availability 70 Fed.Reg. 62137
AGA Comments on Texas Regional Conditions for Nationwide Permits (Nov. 27, 2006)
AGA Comments on Proposed Wetland Nationwide Permits (Nov. 27, 2006)
AGA Comments on Georgia Regional Conditions for Nationwide Permits (Nov. 24, 2006)
AGA Comments on EPA Engine NSPS & NESHAP Proposed Rule (Oct. 11, 2006)
AGA Comments on Draft Environmental Impact Statement (DEIS) for the Seminoe Road Gas Development Project
AGA Comments on Dept. of the Interior Strategic Plan for Gas Production in 2007-2012 (Oct.20, 2006)
AGA Comments on BLM Proposal to Amend EIS for Gas Production in White River Field Office, Colorado (Sept. 29, 2006)
AGA Comments on BLM Fishlake EIS for Gas Production (Aug. 10, 2006)
June 12, 2006 USWAG Letter to EPA Requesting Opportunity to Comment on EPA’s PCB Site Revitalization Guidance
AGA-Industry Amicus Brief to U.S. Supreme Court Supporting Duke Energy in NSR Case (Sept. 15, 2006)
AGA Comments Regarding the US Forest Service Proposed Categorial Exemption Proposal Pertaining to NEPA Documentation Required for Oil and Gas Activities
AGA Comments on BLM Hiawatha Energy Development Plan in Wyoming (Oct. 19, 2006)
AOPL Comments on Proposed Wetlands Nationwide Permits (Nov. 27, 2006)
Government Links
Prior to 2006

 Joint USWAG-AGA Comments on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006) 

On February 10, 2006 the Utility Solid Waste Activities Group (“USWAG”) submitted comments in response to EPA’s request for comments on the “SPCC Guidance for Regional Inspectors” (“SPCC Guidance”).  USWAG's comments detailed concerns about portions of the SPCC Guidance.  First, USWAC notes that the document fails to distinguish between regulatory requirements that predate the July 17, 2002 SPCC amendments (67 Fed. Reg. 47042) and additions to the regulations promulgated in 2002 for which compliance is being deferred until October 31, 2007.  Second, USWAG noted concerns that the guidance appears to identify as SPCC requirements compliance expectations that do not exist in the regulations and therefore inaccurately expand the universe of facilities requiring SPCC plans.  Additionally, USWAG noted that using guidance documents to change or impose de facto regulatory requirements runs afoul of section 4 of the Administrative Procedure Act, as codified at 5 U.S.C. § 553(b) (requiring notice and comment rulemaking for formulating and amending a rule) and has recently been the subject of criticism by the Office of Management and Budget (“OMB”).
 

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