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2012
AGA Comments on the EPA Stormwater Notice March 5, 2012
AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012)
Regulating Construction Site Stormwater Discharges with a Strong Statewide Program in Alabama (Dec. 3, 2012)
Federal Agency Leadership of Environmental Consultations for Natural Gas Projects (Dec. 10, 2012)
AGA Comments on Water Resources Permitting in California for Natural Gas Projects (Dec. 7, 2012)
AGA Comments on Pennsylvania Natural Diversity Index Tool for Environmental Permits (Dec. 3, 2012)
Comments on EPA’s PCB Transportation Manifest Rules (Nov. 5, 2012)
Sierra Club v. Bostick – Briefs to 10th Circuit in Appeal of Order Denying Motion for Injunction (Oct. 2012)
Courts Deny Sierra Club’s Motions for Injunction (Aug. 29, 2012)
Comments on EPA’s Draft Environmental Justice Best Practices for Permit Applicants (Aug. 27, 2012)
AGA Joins Multi-Industry Letter to Senate on TSCA Legislation (Aug. 21, 2012)
AGA Comments on EPA Proposal to Amend NESHAPS for Reciprocating Internal Combustion Engines (Aug. 9, 2012)
Sierra Club v Bostick - AGA Moves to Intervene in Support of Streamlined Utility Wetlands Permit (July 30, 2012)
Court Grants AGA's Motion to Intervene in Sierra Club v. Bostick (Aug. 1, 2012)
AGA Comments on EPA GHG Subpart W Reporting Rule Technical Corrections (June 20, 2012)
AGA Comments on EPA Subpart W Greenhouse Gas Confidential Business Information & Reporting Deferral Proposed Rule (April 9, 2012)
AGA Comments on Major Source Boiler MACT Proposed Rule (Feb. 21, 2012)
AGA Court Challenge to GHGReporting Rule Subpart W Technical Revisions (Feb. 21, 2012)
AGA Supports SoCalGas’ Challenge to California Anti-LNG Rule (Jan. 4, 2012)
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Prior to 2006

 AGA Comments on EPA Proposal to Amend NESHAPS for Reciprocating Internal Combustion Engines (Aug. 9, 2012) 

On August 9, AGA filed a comment letter with EPA supporting implementation of recent INGAA-EPA settlement agreements through an EPA rulemaking, particularly the revision of NESHAP rules for reciprocating internal combustion engines (“RICE”) located at “area sources.”  See National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines; New Source Performance Standards for Stationary Internal Combustion Engines, EPA-HQ-OAR-2008-0708 (NOPR issued June 7, 2012).

AGA’s comments stated that EPA’s proposed revisions will be more workable for our members’ “RICE” at area sources, particularly at remote locations.   We also indicated support for comments filed by Laclede Gas Company requesting relief under the limited use engine exemption and additional relief for emergency engines at area source natural gas storage fields associated with natural gas distribution, and for area source engines where there are 5 or fewer offsite residential buildings within a 0.25 mile radius.  AGA also asked EPA to generally allow a limited use RICE exemption for area sources similar to that allowed for major sources under the current rules, and to exclude limited use RICE (those that operate less than 100 hours per year) from emissions and operations limits entirely, whether located at major or area sources.

 AGA RICE Comments (Aug. 9, 2012)
 Laclede Gas Company RICE Petition to EPA (March 30, 2012)
 Laclede Gas Company - RICE Comments (Aug. 9., 2012)
 INGAA RICE Comments (Aug. 9, 20120)

 
 

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