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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 Petition for Reconsideration of Subpart W (March 2, 2011) 

Due to unclear terms and requirements that were newly adopted by EPA in the final rule, AGA utility members are unable to determine with assurance how to comply with the Subpart W rule.  This lack of clarity will likely result in the submittal of conflicting and unreliable emissions data and, thereby, undermine the purposes of Subpart W.  AGA and its members did not have an opportunity to submit comments on these issues during the comment period on the proposed rule, because the new terms and requirements were not included in the proposed rule.   AGA believes these problems can be resolved if EPA allows an opportunity for AGA to provide its comments and proposed solutions to EPA.  AGA is therefore petitioning for EPA’s reconsideration of the Subpart W final rule. 

The cover letter and petition are posted under Environmental Comments and can be accessed by clicking here.


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