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2011
AGA Comments on EPA's Air Emissions Standards for the Natural Gas Sector (Nov. 30, 2011)
AGA Files Comments with SEAB on Shale Gas Development
AGA Files Comments on EPA's Subpart W Proposed Technical Revisions (Oct. 24, 2011)
AGA Comments Supporting NiSource’s 50-Year Habitat Conservation Plan (Oct. 11, 2011)
AGA Comments to NAS on How to Reform the Tax Code to Reduce Greenhouse Gas Emissions & Apended NAS Report on Full Fuel Cycle Energy Efficiency (Sept. 20, 2011)
AGA Comments on EPA Proposed Corrections to Subpart W Greenhouse Gas Reporting Rule (Sept. 19, 2011)
EPA Science Advisory Board Grants Deadline Extension for Comments on PCB Expert Panel (August 9, 2011)
Coalition Request to EPA for Extension of Time to Comment on Expert Panel (August 5, 2011)
AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)
AGA/EPA Boiler MACT Letters re Sierra Club Petition for Reconsideration (July 2011)
AGA Comments on Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011)
AGA Questions to EPA Ozone Review Panel (March 14, 2011)
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)
Presentation from AGA-OTC Webinar on Compressors (Feb. 1, 2011)
AGA-ANGA Comments on EPA Greenhouse Gas Proposal for Trucks (Jan. 31, 2011)
AGA-ANGA Comments on NHTSA Fuel Economy Standards for Trucks (Jan. 31, 2011)
AGA Petition for Subpart W Judicial Review (Jan. 28, 2011)
EPA Response to AGA Questions on Subpart W (Jan. 25, 2011)
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Prior to 2006

 AGA Comments on Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities (July 11, 2011) 

On July 11, 2011 AGA submitted comments on EPA's Draft National Pollutant Discharge Elimination (NPDES) General Permit for Stormwater Discharges from Construction Activities. AGA appreciates EPA's phased approach to changing its stormwater rules, and requests that EPA utilize AGA's stakeholder comments to assess compliance burdens imposed by the Proposed Construction General Permit. For example, the Draft Permit’s stringent, all-encompassing approach imposes unique and disproportionate burdens on natural gas utility construction. EPA should recognize that the Draft Permit addresses stormwater pollution concerns regarding increased impermeability from large-scale construction impacts. Linear natural gas projects should be regulated under a different regime than traditional land development activities, and should certainly not be subject to post-development stormwater controls. AGA strongly believes that both the regulated utilities and state/local regulators would benefit from EPA’s adoption of a best practices or alternative permitting approach that properly captures small pipeline projects’ construction footprint and operational constraints on ROW territory. AGA respectfully requests that EPA modify its approach to linear construction for the purpose of this permit and provide further guidance and rulemaking activity as it pertains to EPA’s direct permitting authority and its authority to supervise states’ permitting programs.
 

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