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2014
AGA- Multi-Association 111(d) Comments to EPA Supporting Combined Heat & Power as a Compliance Option (Oct. 27, 2014)
DOE Quadrennial Energy Review (QER) – AGA’s Comments (Oct. 10, 2014)
Critical Habitat Proposed Rule – AGA Comments Seek Changes to Facilitate Gas Utility Projects (Oct. 9, 2014)
White House Plan to Streamline Permits for Energy Infrastructure and AGA Comments (Oct. 9, 2014)
AGA Seeks Even-Handed Approach to Energy Rights of Way on Indian Land (Oct. 2, 2014)
AGA Testimony on Expediting Permitting for Natural Gas Infrastructure (August 14, 2014)
AGA Comments on EPA’s Revised “Subpart W” Methane Emissions Reporting Rule (April 24, 2014)
Comments on EPA’s “Options” for Revising PCB Rules for Gas Utilities (March 10, 2014)
AGA Preliminary Comments on EPA Natural Gas Gold STAR Proposal for Natural Gas Distribution
AGA Comments on EPA Methane White Paper: Oil and Natural Gas Sector Leaks
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Prior to 2006

 AGA Comments on EPA’s Revised “Subpart W” Methane Emissions Reporting Rule (April 24, 2014) 

On April 24, AGA filed comments on EPA’s proposal to revise and clarify the greenhouse gas reporting rules for natural gas systems under 40 C.F.R. Part 98, Subpart W.  We thanked EPA for making the clarifying changes we sought in our court challenge and petition for administrative review of the 2012 version of Subpart W.  Specifically, EPA proposed to make it clear that natural gas utilities should calculate emissions from metering and regulating (M&R) stations based on meter-regulator runs, rather than burdensome counts of individual components at stations that reduce pressure from transmission to distribution pressure (T-D stations).  In our comments, AGA suggested a few additional corrections and technical clarifications, but overall,  we are pleased that EPA has proposed revisions that will help make the reporting rule more workable for natural gas utilities.
 

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