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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USWAG-AGA Comments on EPA Draft Guidance for Sampling Non-Liquid PCBs (March 29, 2013)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-USWAG Letter to EPA on PCBs (Feb. 22, 2013) 

Counsel for AGA and USWAG met with EPA leadership on Feb. 14, 2013 to discuss a disturbing development regarding an assertion by EPA Region 5 related to the meaning of the term “potential source” as used in the PCB regulations for natural gas pipeline systems.  The scope of this term is important, because the PCB use authorization regulations impose more requirements on pipeline systems containing a “potential source” than on those that lack a “potential source” of PCBs.  We were concerned that EPA Region 5 was attempting to revise the meaning of this term, in direct conflict with long-standing EPA interpretive guidance.  As noted in our Feb. 22 letter following up on the meeting, we were pleased that EPA agreed with us and confirmed that the Agency continues to follow the interpretation of the term “potential source” set forth in EPA’s PCB Question and Answer Manual (“Q&A Manual”), which expressly limits the scope of this term.  A copy of relevant guidance text is attached to the letter.

 AGA-USWAG Follow-up Letter


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