Archive

Show Filters
INGAA Comments to EPA’s GHG Mandatory Reporting Rule Subpart W Reproposal

INGAA member companies transport more than 90 percent of the nation’s natural gas, through… Read More

INGAA Petition for Reconsideration – National Emission Standards for Hazardous Air Pollutants for Reciprocating Internal Combustion Engines

       Pursuant to Clean Air Act (“CAA”) section 307(d)(7)(B), 42 U.S.C. § 7607(d)(7)(B), and for the reasons set forth below, the Interstate… Read More

INGAA’s Comments to GHG Mandatory Reporting Rule Regarding Subparts A and C

 INGAA member companies transport more than 85 percent of the nation’s natural gas, through… Read More

INGAA’s Written Comments to PCB ANPRM

 INGAA’s comments to the EPA’s ANPRM are in large part founded on the collective experience, knowledge, and expertise of its constituent members. Altogether, INGAA’s membership represents many decades of practical, hands-on experience… Read More

Prevention of Significant Deterioration (PSD): Reconsideration of Interpretation of Regulations that Determine Pollutants Covered by the Federal PSD Permit Program

INGAA submits this comment letter pursuant to the notice issued by the Environmental Protection Agency (“EPA”) on September 30, 2009, and published in the Federal Register on October 7, 2009, (the “Reconsideration… Read More

Prevention of Significant Deterioration (PSD) and Title V Permits Issued Under the Clean Air Act (CAA)

The Interstate Natural Gas Association of America (“INGAA) submits these comments regarding the… Read More

INGAA Comments to U.S. EPA proposed Rule

INGAA is concerned that the NO2 NAAQS Proposal could result in onerous regulatory requirements for NOx sources throughout the U.S., without commensurate societal benefit or compelling evidence that the proposed 1-hour standard is necessary to protect public health and welfare.  In addition, NO2 will continue… Read More

Endangered Species Act Section 7 Comments

INGAA’s members and the Services have a mutual interest in improving the efficiency of the conference and consultation processes implementing section 7 of the Endangered Species Act (“ESA”).  For interstate pipelines, improved efficiency speeds the ESA consultation process and makes it more predictable and less costly.  For the Services, improved… Read More

Natural Gas Council Comments to EPA: GHG Emissions Reporting Rule

NGC understands EPA’s goal in developing the Proposed Rule is to obtain data of sufficient quality to support climate change policies and regulations, while at the same time minimizing the Proposed Rule’s… Read More

INGAA Comments to EPA: GHG Emissions Reporting Rule

EPA proposed a rule for the mandatory reporting of greenhouse gases (hereinafter referred to as the GHG Reporting Rule) in the Federal Register on April 10, 2009. The GHG Reporting Rule revises a… Read More

INGAA Comments to EPA: ICE NESHAP Revisions Proposed Rule

The Interstate Natural Gas Association of America (INGAA), submits comments on the U.S. Read More

SPCC Support Letter Request for a Minimum One Year Extension of Implementation Date

With all of the amendments and changes to the SPCC rule, the regulated community is placed in a race against time to comply, assuming the current 2009 implementation dates are not extended. The amendments have significantly altered many elements of the 2002 SPCC rule, which will require fiscal planning and… Read More

INGAA Comments to EPA: Effluent Limitations Guidelines

The Interstate Natural Gas Association of America (“INGAA”) submits the following comments in response… Read More

Performance Specification and Quality Assurance Requirements for Continuous Parameter Monitoring Systems and Amendments to Standards of Performance for New Stationary Sources

  INGAA members operate equipment that requires continuous parameter monitoring systems (CPMS) for compliance assurance.  The proposed requirements in 40 CFR 60, Appendix B, Performance Specification 17 (PS 17) and 40 CFR 60, Appendix F, Procedure 4 (Procedure 4) will affect INGAA member operations.  INGAA comments discuss our concern that… Read More

INGAA Comments to the U.S. Environmental Protection Agency Advance Notice of Proposed Rulemaking (ANPR) regulating greenhouse gases under the Clean Air Act (CAA)

On July 30, 2008, the EPA issued an Advance… Read More

Interagency Cooperation Under the Endangered Species Act INGAA Letter 11-3-08

The Interstate Natural Gas Association of America supports the… Read More

Islander East No. 08-367 Supreme Court Brief Amici Curiae 10-23-08

Amici Curiae of INGAA, NGSA, AGA and IPAA in support of Petitioner Islander East Pipeline Company. In PUD No. 1 of Jefferson County v. Washington Dep’t of… Read More

Stormwater Permitting INGAA�s 9th Cir. Amicus Curiae Letter 7-31-08

INGAA moves for leave to file an amicus curiae letter supporting the Environmental Protection Agency’s “Petition for Rehearing, With a Suggestion for Rehearing En Banc,” filed July 21, 2008.  In this case, a majority of the Panel in NRDC v. Read More

INGAA Comments – Combined Engine Rule – June 12

Comments on the U.S. EPA’s proposed rule Standards of Performance (New Source Performance Standards (NSPS)) for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants (NESHAP) for… Read More

General Conformity Regulations

The Clean Air Act (CAA) general conformity provisions state that: No department, agency or instrumentality of the Federal Government shall engage in, support in any way or provide financial assistance for, license or approve any activity which does not conform to a [CAA] state implementation plan [SIP] after it has… Read More