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2012
AGA Comments on the EPA Stormwater Notice March 5, 2012
AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012)
Regulating Construction Site Stormwater Discharges with a Strong Statewide Program in Alabama (Dec. 3, 2012)
Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012)
AGA Comments on Water Resources Permitting in California for Natural Gas Projects (Dec. 7, 2012)
AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012)
Comments on EPA’s PCB Transportation Manifest Rules (Nov. 5, 2012)
Sierra Club v. Bostick – Briefs to 10th Circuit in Appeal of Order Denying Motion for Injunction (Oct. 2012)
Courts Deny Sierra Club’s Motions for Injunction (Aug. 29, 2012)
Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012)
AGA Joins Multi-Industry Letter to Senate on TSCA Legislation (Aug. 21, 2012)
AGA Comments on EPA Proposal to Amend NESHAPS for Reciprocating Internal Combustion Engines (Aug. 9, 2012)
Sierra Club v Bostick - AGA Moves to Intervene in Support of Streamlined Utility Wetlands Permit (July 30, 2012)
Court Grants AGA's Motion to Intervene in Sierra Club v. Bostick (Aug. 1, 2012)
AGA Comments on EPA GHG Subpart W Reporting Rule Technical Corrections (June 20, 2012)
AGA Comments on EPA Subpart W Greenhouse Gas Confidential Business Information & Reporting Deferral Proposed Rule (April 9, 2012)
AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)
AGA Court Challenge to GHGReporting Rule Subpart W Technical Revisions (Feb. 21, 2012)
AGA Supports SoCalGas’ Challenge to California Anti-LNG Rule (Jan. 4, 2012)
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Prior to 2006

 AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012) 

In comments filed on Dec. 28, 2012, AGA urged EPA to go back to the drawing board on proposed amendments to the new source performance standards (NSPS) for stationary combustion turbines.  AGA expressed appreciation for EPA’s attempt to promote energy efficiency by recognizing the environmental benefit of natural gas combined heat and power (CHP) and combined cycle turbines,  However, we expressed deep concern that in attempting to promote CHP, EPA proposed rule revisions that would seriously increase costs and burdens on simple cycle turbines that compress and move natural gas through intrastate and interstate transmission pipelines.  AGA supported INGAA’s detailed comments in this regard.  In particular, we agreed with INGAA that EPA should not impose new restrictions on offsite overhaul of existing compressor turbines.  We also agreed that EPA should not adopt the proposed new definition of “combustion turbine engine,” because this would significantly alter the determination of how much repair would be considered a “reconstruction” of the turbine, thus triggering stringent “new source” standards for existing turbines.  Both AGA’s and INGAA’s comments are linked below.

AGA Comments
INGAA Comments

 
 

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