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2011
AGA Comments on EPA's Air Emissions Standards for the Natural Gas Sector (Nov. 30, 2011)
AGA Files Comments with SEAB on Shale Gas Development
AGA Files Comments on EPA's Subpart W Proposed Technical Revisions (Oct. 24, 2011)
AGA Comments Supporting NiSource’s 50-Year Habitat Conservation Plan (Oct. 11, 2011)
AGA Comments to NAS on How to Reform the Tax Code to Reduce Greenhouse Gas Emissions & Apended NAS Report on Full Fuel Cycle Energy Efficiency (Sept. 20, 2011)
AGA Comments on EPA Proposed Corrections to Subpart W Greenhouse Gas Reporting Rule (Sept. 19, 2011)
EPA Science Advisory Board Grants Deadline Extension for Comments on PCB Expert Panel (August 9, 2011)
Coalition Request to EPA for Extension of Time to Comment on Expert Panel (August 5, 2011)
AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)
AGA/EPA Boiler MACT Letters re Sierra Club Petition for Reconsideration (July 2011)
AGA Comments on Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011)
AGA Questions to EPA Ozone Review Panel (March 14, 2011)
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)
Presentation from AGA-OTC Webinar on Compressors (Feb. 1, 2011)
AGA-ANGA Comments on EPA Greenhouse Gas Proposal for Trucks (Jan. 31, 2011)
AGA-ANGA Comments on NHTSA Fuel Economy Standards for Trucks (Jan. 31, 2011)
AGA Petition for Subpart W Judicial Review (Jan. 28, 2011)
EPA Response to AGA Questions on Subpart W (Jan. 25, 2011)
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Prior to 2006

 AGA Files Comments on EPA's Subpart W Proposed Technical Revisions (Oct. 24, 2011) 

On October 24, AGA filed comments on the Environmental Protection Agency’s Technical Revisions proposal for the Natural Gas Systems Category (Subpart W) of its Mandatory Reporting Rule for Greenhouse Gases. See EPA Docket Id. No. EPA-HQ-OAR-2011-0512 76 Fed. Reg. 56,010 (Sept. 9, 2011) (“Proposal”). In this Proposal, EPA sought to address several issues that AGA raised earlier this year in a Petition for Reconsideration of EPA’s Final Rule for greenhouse gas reporting for natural gas systems, submitted on March 2, 2011. EPA has attempted to provided clearer definitions for the system components subject to annual component leak surveys. AGA’s’ comments expressed several concerns about the dramatic shift in the type and number of stations that would be subject to the annual leak survey requirement under the Proposal, and suggested clarifications and exclusions. AGA also expressed concerns that the new requirements from this proposal would be finalized no earlier than December 2011, and yet appear to apply retroactively to the 2011 reporting year. To remedy this reporting gridlock, AGA asked EPA to clarify that local distribution companies charged with leak survey reporting under the existing Subpart W rule may choose to submit leak surveys already underway and/or apply an emission factor to a count of stations under the Best Available Monitoring Methods (BAMM) provisions. See 76 Fed. Reg. at 56,032. For more information, contact Pamela Lacey at placey@aga.org.

 

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