Skip Navigation Links
2014
2013
2012
2011
2010
2009
2008
2007
AGA Comments on EPA’s “Loose Ends” SPCC Proposed Rule (Dec. 14, 2007)
USWAG-AGA Comments on EPA’s “Loose Ends” SPCC Proposed Rule (Dec. 14, 2007)
AGA’s Nov. 30, 2007 Comments on The Climate Registry General Reporting Protocol
AGA Comments on EPA Approaches to Greenhouse Gas Emissions Under The Energy Star Program - July 30, 2007
AGA Comments on California PUC Climate Change Proposal for Gas Utilities - July 26, 2007
AGA's Comments on EPA's Residual MACT Advance Notice re: Air Toxics Rules for Natural Gas Tranmission and Storage (June 29, 2007)
EPA Scoping Paper on Approaches to Greenhouse Gas Emissions Under The Energy Star Program - June 2007
AGA Comments on EPA’s Proposal to Drop the “Once-In-Always-In” MACT Policy (May 4, 2007)
AGA's Comments on BLM's Draft Supplemental EIS for Natural Gas Production in Pinedale, Wyoming (April 6, 2007)
AGA' sComments on California Climate Action Registry (CCAR) Discussion Paper for a Natural Gas Tranmission and Distribution Reporting Protocol (March 16, 2007)
AGA's Comments on EPA's Proposal to Extend the Compliance Deadline for the July 2002 SPCC Rule (Jan. 25, 2007)
AGA's Response to GAO Questionaire on EPA's SPCC Rule (Jan. 19, 2007)
AGA Comments on DHS Chemical Facility Anti-Terrorism Standards Proposed Rule
2006
Government Links
Prior to 2006

 AGA Comments on EPA’s “Loose Ends” SPCC Proposed Rule (Dec. 14, 2007) 

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.
 

Join the Energy Conversation