On January 21, 2010, INGAA, IPAA, and NGSA sent a letter to EPA Administrator Lisa Jackson concerning the EPA Tailoring rule’s impact on natural gas infrastructure projects. Specifically, the application of PSD and Title V to natural gas infrastructure will cause permitting delays impeding capital projects for all segments of the natural gas industry and the application of best available control technology (“BACT”) standard for GHG emissions from natural gas combustion is difficult given that natural gas combustion in itself represents BACT when it is used in power generation and industrial applications.
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