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AGA Comments on EPA Greenhouse Gas PSD Tailoring Proposed Rule (Dec. 27, 2009)
AGA Cover Letter for PCB Response to EPA (Nov. 18, 2009)
AGA PCB Response to EPA (Nov. 18, 2009)
Engine Air Toxics (RICE MACT) Final Rule Postponed (Nov. 9, 2009)
USWAG Letter Supporting GE Comments on PCB Dioxin-Like Toxic Equivalence Guidance (Oct. 28, 2009)
USWAG Letter to EPA re Environmental Justice NY PCB Building Caulk Suit (Oct. 27, 2009)
EPA Presentation Outlining New Greenhouse Gas BACT Guidance (Oct. 7, 2009)
AGA Comments Urging DOE to provide ARPA-E funding (Sept. 25, 2009)
AGA Letter to CEQ Urging Inclusion of Source Energy in Executive Order - Sept. 4, 2009
AGA Comments on EPA Finding of Endangerment – Climate Change Proposal (June 23, 2009)
AGA Letter to Carol Browner on Climate and Source Energy (June 17, 2009)
AGA Comments on EPA's Greenhouse Gas Reporting Rule (June 9, 2009)
AGA Comments on EPA Proposed Hazardous Air Pollutant Standards for RICE Engines (June 3, 2009)
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Prior to 2006

 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 be 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.


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