On December 14, 2007 AGA submitted comments on EPA’s proposed amendments to the Spill Prevention, Control, and Countermeasure (SPCC) regulations, 72 Fed. Reg. 58378 (Oct.15, 2007) (“loose ends” proposal). In addition to joining in comments filed by USWAG on the loose ends proposal, AGA submitted a separate comment letter to address two issues specific to natural gas utility and pipeline systems. First, AGA indicated its support that EPA and the Department of Transportation (DOT) “have committed to revise or augment their 1971 MOU to more clearly define the jurisdictional scope over oil and gas related infrastructure by delineating the specific equipment and appurtenances that are part of the pipeline system subject to DOT jurisdiction” and not subject to EPA’s SPCC program. Second, AGA requested that EPA clarify in the preamble to the final loose ends rule and in the revised Guidance that the various types of odorant used in natural gas systems as a safety measure are not “oils” within the meaning of the SPCC regulations, as defined in 40 C.F.R. §112.2.