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Court Rejects Sierra Club’s Challenge to NWP 12 Wetlands Permit (December 30, 2013)
AGA/Coalition Amicus Brief in Wetlands Permitting Case – Mingo Logan v. EPA (December 13, 2013)
AGA Comments on EPA NPDES Electronic Reporting Rule Proposal (October 28, 2013)
AGA Comments on 2014 State Department Climate Action Plan (October 24, 2013)
AGA Opposes DOE’s Use of a new “Social Cost of Carbon” in Appliance Standards Absent Notice and Opportunity to Comment
AGA Comments to the OMB Interagency Steering Group under Executive Order 13604 – Modernizing Natural Gas Permitting (July 31, 2013)
Vapor Intrusion Guidance - AGA Comments Ask EPA to Delete References to Pipelines
AGA Comments on EPA Proposal to Modify Construction Stormwater Discharge Rules (May 31, 2013)
AGA Letter to CEQ Supports PGE Comments on Streamlining Federal and California Environmental Review Process (April 19, 2013)
USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013)
AGA Comments on EPA 2013 Draft Inventory of Greenhouse Gas Emissions (March 25, 2013)
AGA-USWAG Letter to EPA on PCBs (Feb. 22, 2013)
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Prior to 2006

 AGA Comments on EPA NPDES Electronic Reporting Rule Proposal (October 28, 2013) 

AGA submitted comments responding to the Environmental Protection Agency’s Notice proposing a nationwide NPDES Electronic Reporting Rule program.  See Proposed Rule, 78 Fed. Reg. 46006 (July 30, 2013).  AGA’s comments supported improvements to the NPDES framework to achieve a consistent nationwide electronic reporting program across all states, tribes and territories that administer the reporting program. Our comments noted that AGA members will be affected by changes to the NPDES reporting program because gas utilities routinely submit documents and information for coverage under state and federal construction stormwater general permits, as well as inspection documentation under those permits for routine utility land disturbances.  Our comments also noted that in addition to state-wide and regional EPA permitting requirements, utilities are often required to submit permitting and compliance information to comply with municipal construction stormwater permitting programs.  Accordingly, our comments requested that EPA issue a supplementary notice for public comment that provides greater specificity to the proposed reporting requirements with regard to any mandatory or “threshold” compliance requirements for all electronic programs. We also requested that any new mandatory reporting requirements should be phased in over a period of time, with provisions to grandfather existing state programs to promote the efficient administration of existing electronic reporting frameworks.   

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