INGAA filed extensive comments November 22 on EPA’s proposed rule, Oil and Natural Gas Sector New Source Performance Standards and National Emission Standards for Hazardous Air Pollutants Reviews. INGAA’s primary concern is that the proposed rule is premature and the need for a volatile organic compound (VOC) applicability threshold for the pipeline sector of the oil and gas industry has yet to been proven. INGAA’s comments address a number of topics associated with the proposed rule’s applicability, standards and implementation.