The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments in response to the Environmental Protection Agency’s (EPA) notice, “Information Collection Request Submitted to OMB for Review and Approval; Comment Request; Information Collection Effort for Oil and Gas Facilities” (Proposed ICR). The notice published on September 29, 2016 (81 Fed. Reg. 66,962) indicates that EPA has submitted the Proposed ICR to the Office of Management and Budget (OMB) for review and approval, and provides a second opportunity for public comment. INGAA previously submitted comments on the initial ICR notice published on June 3, 2016 (81 Fed. Reg. 35,763). The Proposed ICR will significantly affect INGAA members, and INGAA welcomes the opportunity to comment.
Natural gas provides 25 percent of the basic energy needs in the United States. INGAA’s members represent the vast majority of the interstate natural gas transmission pipeline companies in the United States, operating approximately 200,000 miles of pipelines, and serving as an indispensable link between natural gas producers and consumers. The North American natural gas pipeline system is an energy highway integral to U.S. energy infrastructure. INGAA and its members have a long history of working collaboratively with a variety of stakeholders on air quality and greenhouse gas (GHG) issues, including on methane. INGAA appreciates your consideration of these comments.