INGAA Comments to EPA: Effluent Limitations Guidelines

The Interstate Natural Gas Association of America (“INGAA”) submits the following comments in response to the U.S. Environmental Protection Agency (“EPA”) Notice of Proposed Rulemaking (“NOPR”) in this docket, 73 Fed. Reg. 72562 (November 28, 2008).

INGAA has reviewed the NOPR in detail and is very concerned about its potential impact of the Proposal on the costs and viability of our interstate natural gas pipeline projects. Consequently, we offer the attached comments to help guide and inform the EPA on the unique nature and challenges that the NOPR presents to our industry. Given the importance of natural gas operations to our Nation’s energy supply, Congress has exempted natural gas pipeline construction activities from the Clean Water Act (“CWA”) stormwater permitting requirements, and only in limited circumstances are permits required. The EPA should clarify the exempt status of interstate natural gas pipeline construction activity.