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Alerts, Agency Documents
Statement of Issues filed for Subpart W Court Case AGA v. EPA (March 2, 2011)
AGA Petition for Reconsideration of Subpart W (March 2, 2011)
AGA Subpart W Comments to EPA (June 11, 2010)
AGA Subpart W Comments to OMB (May 12, 2010)
AGA Overview and Chart of Current Leak Survey & Repair Rules (May 12, 2010)
AGA Presentation Slides for Meeting with EPA on Greenhouse Gas Subpart W Proposed Rule (May 6, 2010)
AGA Testimony on EPA Proposed Greenhouse Gas Reporting Rule for Natural Gas Facilities – Subpart W (April 19, 2010)
AGA Comments on EPA Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change (March 25, 2010)
AGA Comments Challenge Site-Based DOE Residential Water Heater Energy Efficiency Standards (Feb. 9, 2010)
AGA Comments on EPA Finding of Endangerment – Climate Change Proposal (June 23, 2009)
AGA Comments on EPA's Greenhouse Gas Reporting Rule (June 9, 2009)
EPA Response to AGA on Climate PSD Tailoring Rule (Feb. 12, 2010)
AGA Letter to EPA Administrator Jackson on PSD Tailoring Rule – Role of Natural Gas in Climate Policy (Jan. 22, 2010)
AGA Comments on EPA Greenhouse Gas PSD Tailoring Proposed Rule (Dec. 27, 2009)
AGA Comments Urging DOE to provide ARPA-E funding (Sept. 25, 2009)
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 AGA Comments on EPA's Greenhouse Gas Reporting Rule (June 9, 2009) 

On June 9, 2009 AGA submitted comments on EPA’s proposed rule on the mandatory reporting of greenhouse gas (GHG) emissions.  The comments note AGA's support of the proposed reporting threshold of 25,000 tons per year of CO2-equivalent GHG emissions from large facilities in all sectors.  AGA detailed the practical problems that would arise from the proposed daily metering and annual calibration requirements.  In addition, AGA noted that EPA verification has worked well in other
Clean Air Act programs; third party verification should not be considered, as it is wasteful, expensive and would not appreciably improve the quality or reliability of GHG emissions reports.

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


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