AGA Comments on EPA NSPS Air Rule for Turbines (Dec. 28, 2012)
In comments filed on Dec. 28, 2012, AGA urged EPA to go back to the drawing board on proposed amendments to the new source performance standards (NSPS) for stationary combustion turbines. AGA expressed appreciation for EPA s attempt to promote energy efficiency by recognizing the environmental benefit of natural gas combined heat and power (CHP) and combined cycle turbines, However, we expressed deep concern that in attempting to promote CHP, EPA proposed rule revisions that would seriously increase costs and burdens on simple cycle turbines that compress and move natural gas through intrastate and interstate transmission pipelines. AGA supported INGAA s detailed comments in this regard. In particular, we agreed with INGAA that EPA should not impose new restrictions on offsite overhaul of existing compressor turbines. We also agreed that EPA should not adopt the proposed new definition of combustion turbine engine, because this would significantly alter the determination of how much repair would be considered a reconstruction of the turbine, thus triggering stringent new source standards for existing turbines. Both AGA s and INGAA s comments are linked below.