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.