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Agency Documents , Alerts, Comments
AGA Comments on EPA Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011)
AGA Comments and Exhibit on EPA’s Notice Seeking “Stakeholder Input; Stormwater Management Including Discharges From New Development and Redevelopment" (Dec. 28, 2010)
AGA Alert: EPA Construction Site Stormwater Final Rule Compliance Date Correction (March 8, 2010)
EPA Final Rule: Effluent Limitations Guidelines and Standards for the Construction and Development Point Source Category (Dec. 1, 2009)
SOS Summary: EPA Storm Water Exemption for “Transmission” (Aug. 2006)
AGA Alert: Notice of NPDES Stormwater Permit for Small Oil and Gas Construction Activities Meeting (April 11, 2005)
AGA Letter to EPA on NPDES General Permit for Storm Water Discharges from Construction Activities (Nov. 19. 2003)
AGA Comments on Proposed NPDES General Permit for Storm Water Discharges from Large and Small Construction Activities (Feb. 3, 2003)
AGA Comments on EPA Proposed Storm Water Standards for Large and Small Construction Projects (Dec. 23, 2002)
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 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. EPA should recognize that the Draft Permit addresses stormwater pollution concerns regarding increased impermeability from large-scale construction impacts. Linear natural gas projects should be regulated under a different regime than traditional land development activities, and should certainly not be subject to post-development stormwater controls. AGA strongly believes that both the regulated utilities and state/local regulators would benefit from EPA’s adoption of a best practices or alternative permitting approach that properly captures small pipeline projects’ construction footprint and operational constraints on ROW territory. AGA respectfully requests that EPA modify its approach to linear construction for the purpose of this permit and provide further guidance and rulemaking activity as it pertains to EPA’s direct permitting authority and its authority to supervise states’ permitting programs.

The comments are posted under the Environmental Comments section and can be accessed by clicking here.

 
 

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