On October 24, AGA filed comments on the Environmental Protection Agency’s Technical Revisions proposal for the Natural Gas Systems Category (Subpart W) of its Mandatory Reporting Rule for Greenhouse Gases. See EPA Docket Id. No. EPA-HQ-OAR-2011-0512 76 Fed. Reg. 56,010 (Sept. 9, 2011) (“Proposal”). In this Proposal, EPA sought to address several issues that AGA raised earlier this year in a Petition for Reconsideration of EPA’s Final Rule for greenhouse gas reporting for natural gas systems, submitted on March 2, 2011. EPA has attempted to provided clearer definitions for the system components subject to annual component leak surveys. AGA’s’ comments expressed several concerns about the dramatic shift in the type and number of stations that would be subject to the annual leak survey requirement under the Proposal, and suggested clarifications and exclusions. AGA also expressed concerns that the new requirements from this proposal would be finalized no earlier than December 2011, and yet appear to apply retroactively to the 2011 reporting year. To remedy this reporting gridlock, AGA asked EPA to clarify that local distribution companies charged with leak survey reporting under the existing Subpart W rule may choose to submit leak surveys already underway and/or apply an emission factor to a count of stations under the Best Available Monitoring Methods (BAMM) provisions. See 76 Fed. Reg. at 56,032. For more information, contact Pamela Lacey at email@example.com.