Piper and Marbury was retained by the INGAA Foundation to provide legal background for the development of positions for a filing on December 6, 1994 proposed revisions to the PCB rules. Ms. Toni Allen of Piper & Marbury assisted INGAA with filings made on May 1, 1995 and June 2 1, 1995. EPA has indicated that they view INGAA’s comments favorably. Unfortunately, EPA’s budget restraints and other impediments have prevented the publication of the final rule until late 1996 or early 1997.
It is clear that without the assistance of The INGAA Foundation, the natural gas pipeline industry would not have received the temporary relief it has so far, nor be in a position to receive permanent regulatory relief from the extremely onerous, inadequate and costly current PCB rules.