AGA filed provided feedback to the California Air Resources Board on its proposed rule for natural gas transmission and underground storage.  AGA’s comments echoed support for the technical comments submitted by INGAA, which argued that continuous ambient and wellhead monitoring for underground storage fields is not technically feasible, that the CARB proposed rule would include leak detection and repair survey requirements that differ unreasonably from established regulatory requirements.

On May 9, 2016, the American Gas Association commented on the U.S. Fish and Wildlife Service's proposed Mitigation Policy. AGA highlighted its concerns with the Service's proposal to apply its Mitigation Policy to actions under the Endangered Species Act.  Such application unnecessary, a departure from the Service's prior position, and would result in inconsistences between the Endangered Species Act and the Mitigation Policy.

On March 15, 2016, AGA provided feedback to EPA on the Agency's proposed revisions to the petroleum natural gas systems source category (Subpart W) of the Greenhouse Gas Reporting Program. Atlthough AGA generally supports the incorporation of new methodologies into the GHGRP that have the effect of providing sources with flexibility in reporting, AGA enouraged EPA not to incorporate into Subpart W the leak survey methods proposed in the New Source Performance Standard (NSPS) Subpart OOOOa for the oil and gas industry.

On February 3, 2016, AGA provided EPA with comments on the Agency’s proposal to incorporate new data on natural gas emissions from the natural gas storage and transmission segments into EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks (GHGI). AGA supported EPA’s proposal to incorporate data from recent studies, but encouraged EPA to move forward on incorporating the data industry is reporting to EPA through the Greenhouse Gas Reporting Program.