Comments and Testimony

AGA Tweets

Really captivating presentation by @ChrisKofinis on how media landscape has changed way we think about crisis prep & response. #AGAMarCom

3 hours ago

Thanks to @PSETalk's Charlie Gadzik for presenting on the impact of a recent #safety campaign. #AGAMarCom

4 hours ago

In 2018 the US is expected to become the world's third-largest exporter of liquefied natural gas (LNG).https://t.co/6AoojG7SBU #natgas #wgc

4 hours ago

 

Environment

Natural gas is highly efficient and has a much smaller environmental impact than other energy sources.

 

ANSI Public Reviews

GPTC - The Accredited Standards Committee (ASC) conducts periodic public reviews on revisions to the GPTC Z380.1-2015, Guide for Gas Transmission, Distribution, and Gathering Piping Systems. The due date for public comments is February 20, 2017. Comments should be emailed to Mike Bellman mbellman@aga.org, Secretary, ASC GPTC Z380. Any questions you may have concerning public reviews please contact Mike as well.

 

Environmental Comments

The American Gas Association represents natural gas distribution companies that deliver clean natural gas to homes and business across the country. As an advocate for natural gas utility companies and their customers, AGA works to inform legislators, regulators, interested stakeholders and the general public on environmental matters that directly affect the natural gas industry.  The comments included in this section address EPA and other federal agency environmental policies and regulations, as well as some state and regional proposals.

Report
 

Natural Gas Vehicles

Using natural gas instead of gasoline or diesel to power vehicles is a low-cost, low-emissions solution for reducing our nation's dependence on foreign energy sources while also reducing greenhouse gas emissions and urban smog.

 

AGA Comments Challenge Site-Based DOE Residential Water Heater Energy Efficiency Standards (Feb. 9, 2010)

On February 9, 2010 AGA submitted comments to express concerns with the Energy Conservation Standards for Residential Water Heaters, Direct Heating Equipment, and Pool Heaters Proposed Rule. AGA states that DOE failed to implement the recommendations of the National Academy of Science s study authorized by the Energy Policy Act of 2005 covering appliance standards and the use of either full-fuel-cycle or extended site energy metrics.

 

AGA Comments on EPA Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change (March 25, 2010)

On March 25, 2010 AGA submitted comments on EPA's Framework for Categorizing the Relative Vulnerability of Threatened and Endangered Species to Climate Change. This analysis is intended to compare the vulnerabilities of threatened and endangered species to climate change, but the Framework does not state how the analysis is intended to be used. AGA's comments request more information regarding how this analysis is planned to be used and how this use is expected to impact the natural gas industry.

 

AGA PCB Testimony at EPA Hearing in Chicago (May 18, 2010)

AGA PCB Testimony at EPA Hearing in Chicago on May 18, 2010. Testimony on EPA s Reassessment of PCB Use Authorizations, Advance Notice of Proposed Rulemaking 75 Fed. Reg. 17645 (April 7, 2010) Docket ID EPA-HQ-OPPT-2009-0757.

 

AGA Subpart W Comments to OMB (May 12, 2010)

On May 12, 2010 AGA submitted comments to OMB on the EPA Proposed Rule, Mandatory Reporting of Greenhouse Gases: Petroleum and Natural Gas Systems. AGA's comments explain why EPA does not need most of the information that AGA member companies would be required to provide under proposed Subpart W. In addition, AGA explained why EPA s burden estimates are orders of magnitude too low.

 

AGA-ANGA Comments on EPA Greenhouse Gas Proposal for Trucks (Jan. 31, 2011)

On January 31, 2011 the American Gas Association (AGA) and the America s Natural Gas Alliance (ANGA) submitted comments on the joint EPA-NHTSA proposed greenhouse gas emission and fuel efficiency regulations for medium- and heavy-duty vehicles (the HD Rule ), 75 FR 74152. These comments urge EPA to allow for the HD Rule s compliance methodology to include the upstream GHG emission benefits of natural gas.

 

AGA-ANGA Comments on NHTSA Fuel Economy Standards for Trucks (Jan. 31, 2011)

On January 31, 2011 the American Gas Association (AGA) and America s Natural Gas Alliance (ANGA) submitted these comments on the proposed fuel efficiency regulations for medium- and heavy-duty vehicles published by the National Highway Traffic Safety Administration (NHTSA) (the HD Rule ) at 75 FR 74152. These comments note that the NHTSA s HD Rule should include the NGV multiplier Congress mandated for light-duty vehicles.

 

AGA Petition for Subpart W Judicial Review (Jan. 28, 2011)

On Friday January 28, 2011, AGA filed a petition for judicial review of EPA s greenhouse gas reporting rule for natural gas systems (40 C.F.R. Part 98, Subpart W) in the U.S. Court of Appeals for the D.C. Circuit. AGA believes it should be possible to reach a settlement and have EPA agree to issue a rule amendment to resolve the relevant issues, but in case that is not possible, by filing this petition, AGA preserves its right to challenge the rule in court.

 

AGA Questions to EPA on Subpart W Greenhouse Gas Reporting Rule (filed Nov. 19, 2010)

Following the release of Subpart W, many distribution operators were unclear regarding portions of the final rule. AGA members worked with AGA staff to detail the ten most common questions being posed. The language developed by AGA members and AGA staff specify what is unclear, what is interpretation is currently understood and what concerns operators have for future implementation.

Presentations and Speeches
 

AGA Presentation Slides for Meeting with EPA on Greenhouse Gas Subpart W Proposed Rule (May 6, 2010)


On May 6, 2010 AGA staff and members met with EPA's staff to clarify concerns regarding the Greenhouse Gas Reporting Subpart W Proposed Rule. AGA detailed members' concerns with the rule's abbreviated timeline and the requirement to survey thousands of facilities of optical scanning equipment that is of limited supply. This presentation intended to clarify the technical concerns and ramifications of the proposed requirements. In addition, AGA and its membership sought to work with EPA to address the intent of this proposed rulemaking.

 

AGA Overview and Chart of Current Leak Survey & Repair Rules (May 12, 2010)


To eduate EPA staff and interested stakeholders regarding existing leak survey requirements, AGA developed two documents to detail federal and state requirements. AGA developed an overview document to that includes examples of state requirements that exceed federal DOT rules. This document also includes information on AGA GPTC Leak Survey Guidelines.

 

AGA Subpart W Comments to OMB (May 12, 2010)


On May 12, 2010 AGA submitted comments to OMB on the EPA Proposed Rule, Mandatory Reporting of Greenhouse Gases: Petroleum and Natural Gas Systems. AGA's comments explain why EPA does not need most of the information that AGA member companies would be required to provide under proposed Subpart W. In addition, AGA explained why EPA s burden estimates are orders of magnitude too low.

 

AGA Subpart W Comments to EPA (June 11, 2010)

On June 11, 2010 AGA submitted comments to EPA on the Mandatory Reporting of Greenhouse Gases Proposed Rule. AGA's comments urge EPA to delete natural gas distribution from the list of industry segments subject to Subpart W. In EPA retains distribution systems in the final rule, then AGA's comments urge EPA (1) to postpone applicability or otherwise phase-in Subpart W, and (2) to revise and clarify several provisions to facilitate implementation and compliance. AGA's comments and attached exhibits are included below:

 

AGA Petition for Reconsideration of Subpart W (March 2, 2011)

Due to unclear terms and requirements that were newly adopted by EPA in the final rule, AGA utility members are unable to determine with assurance how to comply with the Subpart W rule. This lack of clarity will likely result in the submittal of conflicting and unreliable emissions data and, thereby, undermine the purposes of Subpart W. AGA and its members did not have an opportunity to submit comments on these issues during the comment period on the proposed rule, because the new terms and requirements were not included in the proposed rule.

 

Statement of Issues filed for Subpart W Court Case AGA v. EPA (March 2, 2011)

On March 2, 2011 AGA filed a non-binding Statement of Issues to be raised in the court case AGA v. EPA. AGA challenges several provision in EPA s mandatory greenhouse gas reporting rule for natural gas systems, because the rule is so vague and confusing that our members cannot determine what the rule requires them to do. In addition, many of the confusing terms and requirements are undefined and appeared for the first time in the final rule, so AGA had no opportunity to comment on them, as required by law.

 

AGA Comments & Exhibits on EPA ANPRM on PCB Use Authorization Reassessment (Aug. 20, 2010)

In response to an EPA proposal to ban all detectible trace of PCBs in all natural gas systems, AGA filed extensive comments demonstrating there is no need to change current practices, which work well to protect people and the environment. There is no justification for EPA s contemplated phase out and elimination of the PCB use authorizations for natural gas systems. Further, it would be physically impossible to completely eliminate all trace of PCBs from natural gas systems.

Top