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Agency Documents , Alerts, Comments
EPA SPCC Rule Fact Sheet: Streamlined Requirements for Tier I and II Qualified Facilities (May 2011)
EPA Extends SPCC Deadline Until Nov. 10, 2011 (Oct. 7, 2010)
USWAG-AGA Comments on EPA’s “Loose Ends” SPCC Proposed Rule (Dec. 14, 2007)
AGA Comments on EPA’s “Loose Ends” SPCC Proposed Rule (Dec. 14, 2007)
EPA SPCC Rule Fact Sheet: Amended SPCC Requirements (Dec. 2006)
AGA Alert: White House Office of Management & Budget Clears Oil Spill Prevention Control & Countermeasure Oil-Filled Equipment & Small Facility Final Rule (Nov. 16, 2006)
Joint USWAG-AGA Comments on EPA Proposed SPCC Rule for Oil-Filled Equipment (Feb. 10, 2006)
Joint USWAG-AGA Comments on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006)
AGA's Separate Comment Letter on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006)
AGA's Separate Comment Letter on EPA Proposed SPCC Rule for Oil-Filled Equipment (Feb. 10, 2006)
EPA SPCC Guidance for Regional Inspectors (Nov. 28, 2005)
Joint Letter from the SPCC Industy Coalition to EPA Requesting an Extention of the SPCC Rule Compliance Dates (Oct. 6, 2005)
AGA Alert: SPCC Update (June 20, 2005)
AGA Alert: EPA’s SPCC 2005 Agenda (Feb. 15, 2005)
AGA Comments on EPA's Proposed One Year SPCC Extension (July 7, 2004)
AGA Alert: EPA Describes Plans for Oil Spill Prevention SPCC Rule at Public Meeting (April 1, 2004)
Senator Inhofe Chastises EPA Regarding SPCC Rule Enforcement & Deadlines (March 25, 2004)
USWAG Comments on 2004 Draft report to Congress on the Costs and Benefits of Federal Regulation (May 20, 2004)
AGA Letter Response to EPA Data Request to Support Natural Gas Transportation Equipment & SPCC Transportation Exemption (Feb. 27, 2004)
AGA Letter to EPA Requesting Natural Gas Transportation Equipment & SPCC Transportation Exemption (Jan. 19, 2004)
AGA Letter to EPA Regarding NPDES General Permit for Storm Water Discharges from Construction Activities (Nov. 19, 2003)
AGA Comments on OPS Best Management Practices for Pipeline Repairs (Sept. 29, 2003)
EPA Final Interim Rule Extending Deadline for Amending SPCC Plans by 60 Days (Jan. 9, 2003)
EPA Proposed Rule to Extend SPCC Deadline by One Year (Jan. 9, 2003)
AGA Alert: EPA Signs SPCC Compliance Deadline Extension (Jan. 6, 2003)
EPA Final Rule: Oil Spill Prevention, Control and Countermeasure (SPCC) Plans for Non-Transportation-Related Onshore and Offshore Facilities (July 12, 2002)
AGA Alert: EPA Signs, then Withdraws Final Rule on Preventing Oil Spills from Tanks (Feb. 7, 2001)
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Presentations

 Joint USWAG-AGA Comments on EPA SPCC Guidance for Regional Inspectors (Feb. 10, 2006) 

On February 10, 2006 the Utility Solid Waste Activities Group (“USWAG”) submitted comments in response to EPA’s request for comments on the “SPCC Guidance for Regional Inspectors” (“SPCC Guidance”).  USWAG's comments detailed concerns about portions of the SPCC Guidance.  First, USWAC notes that the document fails to distinguish between regulatory requirements that predate the July 17, 2002 SPCC amendments (67 Fed. Reg. 47042) and additions to the regulations promulgated in 2002 for which compliance is being deferred until October 31, 2007.  Second, USWAG noted concerns that the guidance appears to identify as SPCC requirements compliance expectations that do not exist in the regulations and therefore inaccurately expand the universe of facilities requiring SPCC plans.  Additionally, USWAG noted that using guidance documents to change or impose de facto regulatory requirements runs afoul of section 4 of the Administrative Procedure Act, as codified at 5 U.S.C. § 553(b) (requiring notice and comment rulemaking for formulating and amending a rule) and has recently been the subject of criticism by the Office of Management and Budget (“OMB”).

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

 
 

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