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INGAA Comments on EPA Oil and Gas ICR Review

  The Interstate Natural Gas Association of America (INGAA) respectfully submits these comments in… Read More

INGAA responds to EPA’s request for information for the Natural Gas Transmission and Storage NESHAP (40 CFR

In November 2011, INGAA commented on proposed amendments. In response to final Subpart HHH amendments published in August 2012, INGAA submitted a request for reconsideration in September 2012. INGAA understands that EPA… Read More

INGAA Comments on EPA Proposed Revisions to Test Methods

The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate… Read More

INGAA comments on EPA’s proposed revisions to the Greenhouse Gas Reporting Rule for Leak Detection Methodology

Summary of INGAA Comments 1. INGAA supports consistency between different regulatory programs in order to reduce redundancies and allow for consistent use of measurement techniques and reporting. 2. This Proposed Rule is premature since it incorporates provisions from… Read More

INGAA urges updates to EPA�s greenhouse gas inventory program

INGAA urged the Environmental Protection Agency to improve its GHG inventory by updating emissions factors and incorporating new data from a joint industry-environmental group-academia study. INGAA noted that data from the Colorado State University-led study, which addressed the issue of super-emitters – a few, large methane releases that account for… Read More

INGAA comments on EPA’s Cross-State Air Pollution Rule Update for the 2008 Ozone NAAQS

INGAA supports EPA proposal not to include non-EGUs among the sources subject to the updated CSAPR. In addition, INGAA urges the Agency to continue seeking information and input from stakeholders regarding the… Read More

INGAA comments on EPA’s proposed rule on the Source Determination for Certain Emission Units in the Oil and Natural Gas Sector

The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to comment on… Read More

INGAA expresses concerns with new methane proposal in comments filed to EPA

INGAA and its members have a long history of working with a variety of stakeholders on greenhouse… Read More

INGAA supports EPA�s decision to propose a voluntary methane emission reduction program

INGAA and its member companies have a long history of working collaboratively with a variety of stakeholders on greenhouse… Read More

INGAA and API file comments on EPA’s Proposed Rule titled �Amendments to Regional Consistency Regulations”

 The U.S. Environmental Protection Agency’s proposed revisions to the existing Regional Consistency Regulations are inconsistent with the authority granted to EPA in the Clean Air Act  and are therefore unlawful and should… Read More

INGAA joins 259 associations in letter urging President Obama to maintain EPA�s ozone protection standard

INGAA joined 259 associations and businesses in a letter urging President Obama to maintain Environmental Protection Agency (EPA)’s existing ozone (smog) protection standard at 75 parts per billion (ppb) rather than making the… Read More

INGAA�s comments to EPA�s Proposed Rule on Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan Requirements

U.S. Environmental Protection Agency Air and Radiation Docket and Information Center Mailcode: 28221T 1200 Pennsylvania Avenue, N.W. Washington, D.C. 20460   Re: “Fine Particulate Matter National Ambient Air… Read More

INGAA Submits Comments on EPA’s Draft GHG Report

  INGAA believes EPA clearly and transparently should explain all changes to the methodology it relies upon to arrive at its National Inventory. All stakeholders should have the ability to understand the… Read More

INGAA recommends that the EPA does not adopt more stringent Ozone regulations.

INGAA recommends that the EPA retain the current 75 part per billion (ppb) ozone NAAQS rather than pursue a more stringent standard. In addressing its concerns, INGAA raises the following specific issues:… Read More

INGAA Comments on EPA Proposed Rule

The Interstate Natural Gas Association of America (INGAA) respectfully submits these comments in response… Read More

INGAA comments on EPA’s Clean Power Rule

INGAA is confident that, subject to certain caveats and assuming that certain preconditions can be satisfied, the interstate… Read More

Comments of the Waters Advocacy Coalition on the Environmental Protection Agency�s and U.S. Army Corps of Engineers� Proposed Rule to Define �Waters of the United States� Under the Clean Water Act EPA-HQ-OW-2011-0880

Deidre G. Duncan Virginia S. Albrecht Kerry L. McGrath Hunton & Williams LLP 2200 Pennsylvania Avenue, NW Washington, DC 20037 (202) 955-1500 Counsel for Coalition   November 13, 2014   The Waters Advocacy Coalition (“WAC” or “Coalition”) writes to provide comments on the Environmental Protection Agency (“… Read More

INGAA Provides Feedback to EPA on the Proposed Natural Gas STAR Gold Program

INGAA and its members have worked with EPA on greenhouse… Read More

INGAA Comments on Pennsylvania Department of Environmental Protection Proposed Rule

Proposed Revisions to 25 PA Code, Chapters 121 and 129, PA Bulletin, Vol. 44, No. 16 (April 19, 2014) Additional RACT Requirements for Major Sources of NOx and VOCs (Proposed Rule) Summary of Comments By the Interstate… Read More