Filings, Letters, and Testimonies

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INGAA Comments on DHS ANPR: Chemical Facility Anti-Terrorism Standards

General Regulatory Approach: In the ANPRM, DHS asks “whether or not commenters think that deletions, additions or modification to the list of exempt facilities should be considered.” 79 Fed. Reg. at 48695. When it enacted the CFATS enabling legislation, Congress was clear that CFATS regulations shall apply to chemical facilities… Read More

INGAA comments on OSHA’s Supplemental Notice of Proposed Rulemaking

In the supplemental notice, OSHA is soliciting comments on whether to amend the proposed rule to require that employers inform their employees of their right to report injuries and illnesses, and that any injury and illness reporting requirements established by the employer must be reasonable and not unduly burdensome. OSHA… Read More

Comments on Three Endangered Species Act Critical Habitat Proposals of the U.S. Fish and Wildlife Service and the National Marine Fisheries Service

On October 9, 2014, as part of an industry coalition, INGAA filed comments in response to the two proposed rules and a policy statement jointly issued by the U.S. Fish and Wildlife Service and the National Marine Fisheries Service.   The proposals would significantly revise the critical habitat review process… Read More

INGAA comments on FERC Commissioner Moeller’s meeting concerning a national electronic information and trading platform for natural gas

On September 18, 2014, Commissioner Moeller convened a meeting to consider a national electronic information and trading platform for… Read More

INGAA comments on FERC Proposed Rulemaking to amend filing requirements for natural gas pipeline maps

The Interstate Natural Gas Association of America (INGAA) submitted comments on September 29, 2014… 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

Don Santa Testifies on H.R. 1587: The Energy Infrastructure Improvement Act.

Don Santa, President & CEO of the Interstate Natural Gas Association of America, testified… Read More

INGAA Comments Regarding Environmental Protection Agency Technical White Papers

Below, please find three links to INGAA’s comments on the following white papers: Environmental Protection Agency (EPA)… Read More

INGAA comments on PHMSA’s Public Workshop on Class Location Methodology

The Interstate Natural Gas Association of America (INGAA), a trade organization that advocates regulatory… Read More

Don Santa Testifies on the Pipeline Safety

 Don Santa, President & CEO of the Interstate Natural Gas Association of America, testified… Read More

INGAA Comments Regarding the Proposed Rule

Background: INGAA filed comments with the U.S. Environmental Protection Agency on April 24 on the agency’s proposed revisions to the greenhouse… Read More

INGAA’s Comments to OSHA’s Request for Information concerning Process Safety Management

Several of the issues raised in OSHA’s RFI may significantly impact INGAA’s members. INGAA appreciates the opportunity to comment on OSHA’s RFI, and is willing to meet with OSHA to address any concerns OSHA may have. PSM Comments 3.31.pdfDownload… Read More

INGAA’s Comments to OSHA’s Notice of Proposed Rulemaking regarding Improved Tracking of Workplace Injuries and Illnesses

Conclusion While transparency in recordkeeping serves a valuable purpose, the Proposed Rulemaking is unreasonable and unnecessarily complicated. OSHA should specify how it will utilize any data it collects. OSHA should also abandon any consideration of enterprise-wide submissions.   For the reasons stated, INGAA respectfully suggests that OSHA modify the Proposed… Read More

Don Santa Testifies on Benefits of and Challenges to Energy Access

 Don Santa, President & CEO of the Interstate Natural Gas Association of America, testified… Read More

INGAA Files Comments to OSHA’s Notice of Proposed Rulemaking regarding Silica

 INGAA believes that OSHA’s current silica standard adequately addresses silica exposure and protects employees in the … Read More

Pipeline Safety: Information Collection Activities

Annual Report: Part C Volume Transported by… Read More

INGAA Files Request for Rehearing on Revisions to Auxiliary Installations

 Pursuant to Section 19 of the Natural Gas Act (“NGA”)  and Rule 713 of… Read More

INGAA Expresses Support for Natural Gas Pipeline Permitting Reform Act in Letter to Congressman Pompeo

November 14, 2013   The Honorable Mike Pompeo 107 Cannon House Office Building Washington, DC  20515   Dear Congressman Pompeo, On behalf of the membership of the Interstate… Read More