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AGA Files Waters of the U.S. Comments and Signs Joint Associations' Letter to the Army Corps of Engineers (November 13, 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

 Comments on EPA’s “Options” for Revising PCB Rules for Gas Utilities (March 10, 2014) 

AGA assisted member company Unitil provide PCB comments in December 2013 and March 2014 as a Small Entity Representative (“SER”) to the Small Business Advocacy Review (SBAR) panel that was convened to evaluate the potential impacts on small entities of EPA’s contemplated revision of the PCB use authorization regulations under 40 C.F.R. Part 761.  The panel includes representatives of the Small Business Administration (SBA), the White House Office of Management and Budget (OMB), and EPA.  In a presentation to stakeholder SERs in December 2013, EPA’s PCB team indicated they were considering whether to  revise the rule to require natural gas utilities to immediately report to the EPA Regional Office  every instance of finding PCBs > 50 ppm anywhere in a system.  EPA also said they were thinking of requiring utilities to report discoveries of PCBs > 50 ppm in customer meters and to specifically state in the rule that the EPA Regional Office would have the power to impose whatever “remediation” action they wished, without limitation and despite the lack of any risk of exposure from condensate inside a meter.   At the December meeting and in our related written comments, AGA and Unitil made the case that EPA’s proposals would impose excessive and unnecessary burdens on gas  utilities without environmental or health benefits.  EPA responded favorably, and in the agency’s February 20, 2014 presentation to the SBAR panel and stakeholder representatives, EPA explained that it is only thinking of requiring real time reporting for instances where PCBs > 50 ppm in or beyond a customer meter, and the agency is considering an option to require an annual report of all samples found in a system > 50 ppm based on documentation that companies would collect in any event.  The agency notably dropped the open-ended remediation option, explaining that remediation issues should be handled by a different office at EPA under the PCB disposal regulations rather than in the use authorization regulations.  In fact, the PCB rule provides a use authorization for PCBs in pipeline systems, defined to include distribution and customer piping.  In our March 10, 2014 comments, we thanked EPA for the practical revisions it has made thus far but urged EPA to allow companies to keep a log and make that available upon request in lieu of an annual reporting requirement.  EPA plans to draft a proposed rule in summer/fall 2014 for publication around November 2014.

 Unitil March 2014 SBAR Comments on PCB Rule Options

 Unitil December 2013 Comments on PCB Rule Options



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