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AGA Comments on EPA Greenhouse Gas PSD Tailoring Proposed Rule (Dec. 27, 2009)
AGA Cover Letter for PCB Response to EPA (Nov. 18, 2009)
AGA PCB Response to EPA (Nov. 18, 2009)
Engine Air Toxics (RICE MACT) Final Rule Postponed (Nov. 9, 2009)
USWAG Letter Supporting GE Comments on PCB Dioxin-Like Toxic Equivalence Guidance (Oct. 28, 2009)
USWAG Letter to EPA re Environmental Justice NY PCB Building Caulk Suit (Oct. 27, 2009)
EPA Presentation Outlining New Greenhouse Gas BACT Guidance (Oct. 7, 2009)
AGA Comments Urging DOE to provide ARPA-E funding (Sept. 25, 2009)
AGA Letter to CEQ Urging Inclusion of Source Energy in Executive Order - Sept. 4, 2009
AGA Comments on EPA Finding of Endangerment – Climate Change Proposal (June 23, 2009)
AGA Letter to Carol Browner on Climate and Source Energy (June 17, 2009)
AGA Comments on EPA's Greenhouse Gas Reporting Rule (June 9, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 3, 2009)
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Prior to 2006

 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 included below:

 
 

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