Environmental Comments

 

Environmental Comments

The American Gas Association represents local energy companies that deliver clean natural gas to more than 64 million customers, or 91 percent of all natural gas customers, throughout the United States.  As an advocate for natural gas utility companies and their customers, AGA works to inform legislators, regulators, interested stakeholders and the general public on environmental matters that directly affect the natural gas industry.  The comments included in this section address EPA and other federal agency environmental policies and regulations, as well as some state and regional proposals.

If you have questions regarding the comments posted or would like to review comments submitted prior to 2006, please contact Pam Lacey, AGA's Senior Managing Counsel, Environment.

AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)

On July 29, 2011, AGA joined in the extensive comments filed by the Water Advocacy Coalition on the Draft Guidance prepared by EPA and the U.S.
AGA Comment Letter on EPA Draft Guidance on Waters of the United States (July 29, 2011)

On July 29, 2011, AGA joined in the extensive comments filed by the Water Advocacy Coalition on the Draft Guidance prepared by EPA and the U.S.
AGA Comments & Exhibits on EPA ANPRM on PCB Use Authorization Reassessment (Aug. 20, 2010)

In response to an EPA proposal to ban all detectible trace of PCBs in all natural gas systems, AGA filed extensive comments demonstrating there is no need to change current practices, which work well to protect people and the environment. There is no justification for EPA s contemplated phase out and elimination of the PCB use authorizations for natural gas systems. Further, it would be physically impossible to completely eliminate all trace of PCBs from natural gas systems.
AGA Comments - AGA Questions to EPA Ozone Review Panel (March 14, 2011)

On March 14, 2011, AGA submitted technical questions to the Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel concerning EPA s reconsideration of the 2008 national ambient air quality standards (NAAQS) for ground-level ozone smog. If EPA makes the ozone NAAQS more stringent, this will create serious compliance problems in parts of the country that have not yet achieved the 2008 version of the air quality standards.
AGA Comments Challenge Site-Based DOE Residential Water Heater Energy Efficiency Standards (Feb. 9, 2010)

On February 9, 2010 AGA submitted comments to express concerns with the Energy Conservation Standards for Residential Water Heaters, Direct Heating Equipment, and Pool Heaters Proposed Rule. AGA states that DOE failed to implement the recommendations of the National Academy of Science s study authorized by the Energy Policy Act of 2005 covering appliance standards and the use of either full-fuel-cycle or extended site energy metrics.
AGA Comments on Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011)

On July 11, 2011 AGA submitted comments on EPA's Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities. AGA appreciates EPA's phased approach to changing its stormwater rules, and requests that EPA utilize AGA's stakeholder comments to assess compliance burdens imposed by the Proposed Construction General Permit. For example, the Draft Permit s stringent, all-encompassing approach imposes unique and disproportionate burdens on natural gas utility construction.
AGA Comments on EPA Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011)

On July 11, 2011 AGA submitted comments on EPA's Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities. AGA appreciates EPA's phased approach to changing its stormwater rules, and requests that EPA utilize AGA's stakeholder comments to assess compliance burdens imposed by the Proposed Construction General Permit. For example, the Draft Permit s stringent, all-encompassing approach imposes unique and disproportionate burdens on natural gas utility construction.
AGA Comments on EPA Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change (March 25, 2010)

On March 25, 2010 AGA submitted comments on EPA s Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change. This analysis is intended to compare the vulnerabilities of threatened and endangered species to climate change, but the Framework does not state how the analysis is intended to be used. AGA's comments request more information regarding how this analysis is planned to be used and how this use is expected to impact the natural gas industry.
AGA Comments on EPA Proposal to Modify Construction Stormwater Discharge Rules (May 31, 2013)

On Friday, May 31, 2013, AGA filed comments with EPA supporting EPA s proposal to remove the numeric turbidity and related monitoring requirements from the Effluent Limitation Guidelines for the Construction Point Source Category. AGA also commented on EPA s proposal to incorporate a definition of infeasible into its storm water permitting regulations that would apply to the 2012 Construction General Permit for storm water discharges.
Please click the link below to view the comments.
AGA Comments on EPA Proposed Corrections to Subpart W Greenhouse Gas Reporting Rule (Sept. 19, 2011)

EPA proposed a few technical corrections to the greenhouse gas mandatory reporting rule that requires natural gas operators to monitor and report their methane leaks (40 C.F.R. Part 98, Subpart W). On Sept. 19, 2011, AGA filed a short comment letter supporting several of the proposed clarifications and corrections to Subpart W, because they should make the rule more workable for AGA members.
AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)

On Feb. 21, 2012, AGA filed comments on EPA's proposed revisions to the hazardous air pollutant standards for industrial and commercial boilers and process heaters.
First, our comments strongly support EPA s proposal to apply a work practice standard (calling for regular tune-ups) for natural gas-fired boilers at major sources, rather than an emissions limit. This is appropriate, because EPA s data for natural gas-fired units show the overwhelming majority of emissions to be below the level that can be accurately quantified by the available test methods.
AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012)

On December 3, the American Gas Association filed comments with the Government Accountability Office regarding the benefits and gaps in a permitting tool administered by the Pennsylvania s Department of Environmental Management (PADEP) which GAO plans to feature in its upcoming report on natural gas project permitting.
AGA Comments on the EPA Stormwater Notice March 5 2012

On March 5, AGA filed comments on EPA's Effluent Limitation Guidelines for stormwater risk management from construction projects. AGA s comments request that EPA exempt natural gas transmission and distribution pipeline construction projects from numeric effluent limits for turbidity and from sampling requirements under the Construction and Development final rule.
AGA Comments on Water Resources Permitting in California for Natural Gas Projects (Dec. 7, 2012)

On December 7, AGA filed the attached comments with the Government Accountability Office s Natural Resources division, explaining water resources permitting programs in California, and the opportunities for expediting natural gas project permits through better coordination between federal, state and local authorities for these permits. Our members provided feedback regarding the overlaps in environmental permits and review for water resources in California.
AGA Comments Supporting NiSource’s 50-Year Habitat Conservation Plan (Oct. 11, 2011)

The American Gas Association filed comments with the U.S. Fish & Wildlife Service supporting an Incidental Take Permit and 50-year Habitat Conservation Plan (HCP) application filed by NiSource, Inc. under the Endangered Species Act (ESA).
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)

The National Academies of Science initiated a study to evaluate how provisions in the U.S. Internal Revenue Code either help or hinder efforts to reduce greenhouse gas emissions. On Sept. 20, 2011, AGA filed comments suggesting how tax provisions could be used to expand the direct use of natural gas in homes, businesses and vehicles, thereby reducing greenhouse gas emissions measured on a full fuel cycle basis.
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.
AGA Files Comments with SEAB on Shale Gas Development

The American Gas Association filed comments on October 26 with the Department of Energy s Secretary of Energy Advisory Board Shale Gas Subcommittee ( Subcommittee ), supporting recommendations in the Subcommittee s 90-day interim report issued August 18, 2011.
AGA-ANGA Comments on EPA Greenhouse Gas Proposal for Trucks (Jan. 31, 2011)

On January 31, 2011 the American Gas Association (AGA) and the America s Natural Gas Alliance (ANGA) submitted comments on the joint EPA-NHTSA proposed greenhouse gas emission and fuel efficiency regulations for medium- and heavy-duty vehicles (the HD Rule ), 75 FR 74152. These comments urge EPA to allow for the HD Rule s compliance methodology to include the upstream GHG emission benefits of natural gas.
AGA-ANGA Comments on NHTSA Fuel Economy Standards for Trucks (Jan. 31, 2011)

On January 31, 2011 the American Gas Association (AGA) and America s Natural Gas Alliance (ANGA) submitted these comments on the proposed fuel efficiency regulations for medium- and heavy-duty vehicles published by the National Highway Traffic Safety Administration (NHTSA) (the HD Rule ) at 75 FR 74152. These comments note that the NHTSA s HD Rule should include the NGV multiplier Congress mandated for light-duty vehicles.
AGA-APGA Comments on EPA Proposed Rule: Boilers and Process Heaters (August 23, 2010)

On August 23, 2010, The American Gas Association ( AGA ) and the American Public Gas Association APGA ) submitted comments on the proposed rule of the Environmental Protection Agency ( EPA ) on National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, 75 Fed. Reg. 32006 (June 4, 2010). AGA and APGA urge EPA to recognize the availability and abundance of America s clean and domestic natural gas resources.
AGA-APGA Comments on EPA Proposed Rule: Boilers and Process Heaters (August 23, 2010)

On August 23, 2010, The American Gas Association ( AGA ) and the American Public Gas Association APGA ) submitted comments on the proposed rule of the Environmental Protection Agency ( EPA ) on National Emission Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and Institutional Boilers and Process Heaters, 75 Fed. Reg. 32006 (June 4, 2010). AGA and APGA urge EPA to recognize the availability and abundance of America s clean and domestic natural gas resources.
AGA-Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)

On July 29, 2011, AGA and the organizations listed on the cover page of these comments ("Coalition") filed comments in response to the Environmental Protection Agency's and U.S. Army Corps of Engineers' Draft Guidance on Identifying Waters Protected by the Clean Water Act (CWA), 76 Fed. Reg. 24,479 (May 2, 2011). Our comments set forth numerous concerns with the new 2011 Draft Guidance. As a threshold matter, unlike prior guidance documents, which were limited to the section 404 program, the Agencies intend the Draft Guidance to apply to the entire CWA.
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)

On July 29, 2011, AGA and the organizations listed on the cover page of these comments ("Coalition") filed comments in response to the Environmental Protection Agency's and U.S. Army Corps of Engineers' Draft Guidance on Identifying Waters Protected by the Clean Water Act (CWA), 76 Fed. Reg. 24,479 (May 2, 2011). Our comments set forth numerous concerns with the new 2011 Draft Guidance. As a threshold matter, unlike prior guidance documents, which were limited to the section 404 program, the Agencies intend the Draft Guidance to apply to the entire CWA.
Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012)

AGA is a member of the NAM Business Network for Environmental Justice and joined in the comments BNEJ filed on August 27, 2012 regarding EPA s June 26, 2012 draft documents entitled (1) Proposed Regional Actions to Promote Public Participationin the Permitting Process and (2) Draft Best Practices for Permit Applicants Seeking EPA-Issued Permits, hereinafter collectively referred to simply as the Draft Guidance.
Comments on EPA’s PCB Transportation Manifest Rules (Nov. 5, 2012)

AGA, as a member of the Utility Solid Waste Activities Group (USWAG), joined in comments filed on Nov. 5, 2012 on EPA s attempt to streamline the rules for shipping PCB waste and hazardous waste. EPA s action is intended to align the requirements for PCB manifests under its Toxic Substances Control Act (TSCA) regulations with the existing hazardous waste manifest regulations adopted under Subtitle C of the Resource Conservation and Recovery Act (RCRA). Both waste programs are administered by EPA s Office of Resource Conservation and Recovery (ORCR).
Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012)

On Dec. 10, AGA filed the attached comments with the Government Accountability Office s Natural Resources division, regarding an opportunity to improve environmental consultations and permitting required for natural gas pipeline and infrastructure projects under the national Endangered Species Act ( ESA ).
GE-AGA-INGAA Comments on Advance Notice of Proposed Rulemaking on PCBs: Reassessment of Use Authorizations (October 18, 2010)

On October 18, 2010, the General Electric Company (GE), the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA) submitted comments to EPA regarding Advance Notice of Proposed Rulemaking on PCBs: Reassessment of Use Authorizations, 75 Fed. Reg. 17645 (Apr. 7, 2010). These comments note that PCB exposures declined dramatically, and will continue to decline as PCB-containing equipment and materials are removed from service and PCB-contaminated sites are remediated.
GE-AGA-INGAA Comments on Advance Notice of Proposed Rulemaking on PCBs: Reassessment of Use Authorizations (October 18, 2010)

On October 18, 2010, the General Electric Company (GE), the American Gas Association (AGA) and the Interstate Natural Gas Association of America (INGAA) submitted comments to EPA regarding Advance Notice of Proposed Rulemaking on PCBs: Reassessment of Use Authorizations, 75 Fed. Reg. 17645 (Apr. 7, 2010). These comments note that PCB exposures declined dramatically, and will continue to decline as PCB-containing equipment and materials are removed from service and PCB-contaminated sites are remediated.
Regulating Construction Site Stormwater Discharges with a Strong Statewide Program in Alabama (Dec. 3, 2012)

On December 3, AGA filed the attached comments with the Government Accountability Office s Natural Resources division, explaining the regulation of construction stormwater under EPA s NPDES program in Alabama. This letter was a response to a request from GAO for more information and documentation regarding membership s experience working with several local permitting entities to authorize construction activities in small townships and counties, in addition to the state-issued NPDES permit for stormwater discharges.
USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013)

AGA joined in comments filed by the Utility Solid Waste Activities Group (USWAG) on EPA s Draft Guidance describing how ship owners and operators should sample PCBs in non-liquids such as paint, caulk and plastics. While gas and electric utilities usually do not own or operate ships, the guidance could have much broader implications.
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.
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