Climate Change Comments


Climate Change Comments

Natural Gas Meeting Future Energy Needs

This page contains all of the recent comments that AGA has submitted regarding climate change. Please note that all environmental comments submitted by AGA are posted on the Environmental Comments page.

If you have questions regarding the comments listed below, please contact Pam Lacey, AGA's Senior Managing Counsel, Environment.



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.
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 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.
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: