INGAA comments to EPA regarding amendments to the NPDES regulations for stormwater discharges

RE:  Docket ID No. EPA-HQ-OW-2002-0068, Proposed Amendments to the NPDES Regulations for Stormwater Discharges Associated with Oil and Gas Exploration, Production, Processing, or Treatment Operations, or Transmission Facilities (71 FR 894).

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 in this docket, 71 Fed. Reg. 894 (January 6, 2006).

INGAA fully supports EPA’s proposal to implement a provision of the Energy Policy Act of 2005 (33 U.S.C. 1362 (2005))  that exempts most stormwater discharges from oil and gas exploration, production, processing, or treatment operations, or transmission facilities, including associated construction activities, from the requirement to obtain NPDES permit coverage.

INGAA also supports EPA’s interpretation of the statutory language ‘‘all field activities or operations’’ [emphasis added] as being applicable to construction of in-field treatment plants and the transportation infrastructure (e.g., crude oil and natural gas pipelines, natural gas treatment plants and both natural gas pipeline compressor and crude oil pump stations) necessary for the operation of most producing oil and gas fields. The transportation infrastructure includes interstate natural gas pipelines and compressor stations which are an integral part of the efficient operation of gas fields.  These facilities ensure that produced gas can reach consumers and ease supply constraints. Such construction activities should be eligible for the CWA section 402(l)(2) exemption from NPDES permitting requirements.

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