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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 the EPA Stormwater Notice March 5 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 Major Source Boiler MACT Proposed Rule (Feb. 21, 2012) 

On Feb. 21, 2012, AGA filed comments on EPA's proposed revisions to the hazardous air pollutant standards for industrial and commercial boilers and process heaters. 

First, our comments strongly support EPA’s proposal to apply a work practice standard (calling for regular tune-ups) for natural gas-fired boilers at major sources, rather than an emissions limit. This is appropriate, because EPA’s “data for natural gas-fired units show the overwhelming majority of emissions to be below the level that can be accurately quantified by the available test methods.” 

Second, we ask EPA to clarify whether residential-style appliances are exempt only when located in "dwellings" - e.g. on a college campus - or also when located in an office building or utility service center.
Third, we thank EPA for removing misleading comments about the availability of natural gas supply and for adding a definition of "curtailment" that excludes situations where a commercial or industrial customer chooses an interruptible contract in order to pay a lower rate for gas service.

 

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