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AGA Questions to EPA on Subpart W Greenhouse Gas Reporting Rule (filed Nov. 19, 2010)
Exhibit to AGA Questions to EPA – GTI OTD Metering & Regulator Emission Factor Report (Nov. 19, 2010)
AGA - ANGA Comments on 2017 Light Duty Vehicle NOI -Docket ID No. EPA-HQ-OAR-0799 (November 19, 2010)
Comments on full-fuel-cycle proposal, EERE-2010-BT-NOA-0028 (October 19, 2010)
GE-AGA-INGAA Cover Letter (October 18, 2010)
GE-AGA-INGAA Comments on Advance Notice of Proposed Rulemaking on PCBs: Reassessment of Use Authorizations (October 18, 2010)
AGA Comments on EPA to Treat Some GHG Report Data as Confidential (Sept. 7, 2010)
AGA Comments on CEQ Draft GHG Reporting Guidance to Federal Agencies (Sept. 1, 2010)
AGA-APGA Comments on EPA Proposed Rule: Boilers and Process Heaters (August 23, 2010)
AGA Comments & Exhibits on EPA ANPRM on PCB Use Authorization Reassessment (Aug. 20, 2010)
AGA Subpart W Comments to EPA (June 11, 2010)
AGA PCB Testimony at EPA Hearing in Chicago (May 18, 2010)
AGA Subpart W Definitions Request to EPA (May 14, 2010)
AGA Overview and Chart of Current Leak Survey & Repair Rules (May 12, 2010)
AGA Subpart W Comments to OMB (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 CEQ’s NEPA Guidance for Categorical Exclusions (April 9, 2010)
AGA Comments on EPA Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change (March 25, 2010)
AGA Comments on EPA Notice Seeking Input on Stormwater Rules (Feb. 26, 2010)
EPA Response to AGA on Climate PSD Tailoring Rule (Feb. 12, 2010)
AGA Comments Challenge Site-Based DOE Residential Water Heater Energy Efficiency Standards (Feb. 9, 2010)
AGA Letter to EPA Administrator Jackson on PSD Tailoring Rule – Role of Natural Gas in Climate Policy (Jan. 22, 2010)
AGA Comments and Exhibit on EPA’s Notice Seeking “Stakeholder Input; Stormwater Management Including Discharges From New Development and Redevelopment" (Dec. 28, 2010)
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Prior to 2006

 AGA Comments & Exhibits on EPA ANPRM on PCB Use Authorization Reassessment (Aug. 20, 2010) 


In response to an EPA proposal to ban all detectible trace of PCBs in all natural gas systems, AGA filed extensive comments demonstrating there is no need to change current practices, which work well to protect people and the environment. There is no justification for EPA’s contemplated phase out and elimination of the PCB use authorizations for natural gas systems. Further, it would be physically impossible to completely eliminate all trace of PCBs from natural gas systems. Any attempt to do so would cost hundreds of billions of dollars, cause severe disruptions in natural gas service to homes, businesses, hospitals, schools, industry and government, and increase rather than decrease risks to human health, safety and the environment. AGA strongly opposes the proposal to phase out and eliminate the PCB use authorizations for natural gas systems.

 Instead, we recommend that EPA work with stakeholders to revise Part 761 to focus the rule on what we believe is EPA’s main concern – to manage and reduce the occurrence of oily liquid condensates in distribution systems to keep them from moving PCBs beyond the customer meter. This would allow both EPA and the regulated community to focus scarce resources on measures that have been shown to be effective.


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