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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AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)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 Petition for Subpart W Judicial Review (Jan. 28, 2011) 

On Friday January 28, 2011, AGA filed a petition for judicial review of EPA’s greenhouse gas reporting rule for natural gas systems (40 C.F.R. Part 98, Subpart W) in the U.S. Court of Appeals for the D.C. Circuit. AGA believes it should be possible to reach a settlement and have EPA agree to issue a rule amendment to resolve the relevant issues, but in case that is not possible, by filing this petition, AGA preserves its right to challenge the rule in court. AGA’s main issues with the rule are as follows: (1) the terms “custody transfer city gate station” and “non-custody city gate station” are subject to conflicting interpretations that make it difficult to comply with the rule; and (2) the formula for calculating emissions from city gate stations contains serious errors that would potentially inflate emissions by a significant amount. It was not possible to comment on these issues during the comment period on the proposed rule, because the terms and formula did not appear in the proposed rule. They appeared for the first time in the final rule published in November.
 

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