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Court Rejects Sierra Club’s Challenge to NWP 12 Wetlands Permit (December 30, 2013)
AGA/Coalition Amicus Brief in Wetlands Permitting Case – Mingo Logan v. EPA (December 13, 2013)
AGA Comments on EPA NPDES Electronic Reporting Rule Proposal (October 28, 2013)
AGA Comments on 2014 State Department Climate Action Plan (October 24, 2013)
AGA Opposes DOE’s Use of a new “Social Cost of Carbon” in Appliance Standards Absent Notice and Opportunity to Comment
AGA Comments to the OMB Interagency Steering Group under Executive Order 13604 – Modernizing Natural Gas Permitting (July 31, 2013)
Vapor Intrusion Guidance - AGA Comments Ask EPA to Delete References to Pipelines
AGA Comments on EPA Proposal to Modify Construction Stormwater Discharge Rules (May 31, 2013)
AGA Letter to CEQ Supports PGE Comments on Streamlining Federal and California Environmental Review Process (April 19, 2013)
USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013)
AGA Comments on EPA 2013 Draft Inventory of Greenhouse Gas Emissions (March 25, 2013)
AGA-USWAG Letter to EPA on PCBs (Feb. 22, 2013)
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 Vapor Intrusion Guidance - AGA Comments Ask EPA to Delete References to Pipelines 

             AGA filed comments on June 21, 2013 urging EPA to delete inappropriate and misleading references to natural gas transmission line leaks in a guidance document intended for analyzing potential “vapor intrusion” from underground plumes of chemicals from subsurface contamination into buildings. EPA dropped this inappropriate reference in guidance for “Assessing and Mitigating the Vapor Intrusion Pathway from Subsurface Sources to Indoor Air” (“SVI Guidance”), which EPA issued in tandem with a second guidance for “Addressing Petroleum Vapor Intrusion at Leaking Underground Storage Tanks” (“PVI Guidance”) (Docket ID No. EPA-HQ-RCRA-2002-0033).  AGA’s comments described the robust program of pipeline safety regulations administered by DOT PHMSA for leak detection and remediation, and noted that this is the appropriate regulatory scheme for addressing pipeline safety, not an EPA site remediation guidance.

AGA also joined in detailed comments of the Utility Solid Waste Activities Group (USWAG) filed on June 24, 2013 on other issues in the two guidance documents that could affect underground storage tanks (UST), site clean-ups and manufactured gas plants (MGPs). The USWAG comments supported AGA’s request to delete references to pipeline leaks or at least clarify that such methane leaks are not the sort of “vapor intrusion” intended to be covered by the guidance. AGA is a member of USWAG.

Click here to view AGA's comments and here to view USWAG's comments.


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