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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AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)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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 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.


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