On December 23, 2001 AGA submitted comments on EPA's Proposed Storm Water Standards for Large and Small Construction Projects. The comments noted that the proposed rule affected AGA member companies because they construct and maintain natural gas pipeline and distribution lines that are subject to construction storm water permitting under both the Phase I and Phase II EPA storm water regulations. Unlike most development projects, natural gas pipeline and utility line projects do not cause any long term changes in storm water runoff because these projects cause only minimal (if any) change original grade or contours, and they do not change the amount of impervious surfaces. AGA recommended that EPA promulgate proposed Option #3 in lieu of proposed Options #1 or #2.
The comments are posted under the Environmental Comments section and can be viewed by clicking here.