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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AGA Comment Letter on Draft Guidance on Waters of the United States (July 29, 2011)
AGA/Coalition Comments on EPA Draft Guidance on Waters of the United States (July 29, 2011)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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 AGA Questions to EPA Ozone Review Panel (March 14, 2011) 

On March 14, 2011, AGA submitted technical questions to the Clean Air Scientific Advisory Committee (CASAC) Ozone Review Panel concerning EPA’s reconsideration of the 2008 national ambient air quality standards (NAAQS) for ground-level ozone smog.  If EPA makes the ozone NAAQS more stringent, this will create serious compliance problems in parts of the country that have not yet achieved the 2008 version of the air quality standards. Local air quality agencies do not have control over tailpipe emissions from cars, buses and trucks – the main source of smog inducing emissions – and they have already imposed stringent limits on stationary sources.  They are now running out of options, particularly in areas such as Southern California where a more stringent ozone standard could require imposing a ban on all combustion – even of clean natural gas.  Ironically, this could lead to increased reliance on imported coal-fired electricity causing increased air pollution and carbon emissions in other states.  

 In light of these unintended consequences, it is important to avoid setting the standard at a level that is overly stringent and not supported by the relevant science.  AGA is asking the Ozone Review Panel to evaluate scientific approaches and assumptions that can affect the stringency of the ozone NAAQS.


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