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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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 AGA Comments on EPA Methane White Paper: Oil and Natural Gas Sector Leaks 

On June 16, 2014, AGA submitted comments to the U.S. Environmental Protection Agency (EPA)'s Office of Air Quality Planning and Standards on the EPA technical white paper on "Oil and Natural Gas Sector Leaks," also known as the "Leaks Paper." This is one of five technical white papers that EPA released on April 15, 2014 for external peer review relating to “potentially significant sources of methane and volatile organic compounds (VOCs)” from the oil and natural gas sector – focusing on operations upstream of natural gas distribution systems. The five white papers evaluate emissions from: (1) production well completions; (2) production well liquids unloading; (3) compressors; (4) pneumatic devices; and (5) equipment leaks “upstream of natural gas distribution systems.”

Since AGA represents natural gas utility companies that operate local distribution systems, the white papers have limited direct applicability to our members’ core business. However, we are concerned that some of the broad assumptions made in the white papers, particularly in the Leaks Paper, are not valid with respect to distribution and could indirectly impact distribution operations. These comments seek to clarify the record and avoid later misunderstandings.


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