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PHMSA Class Change NPRM Comments

The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), GPA Midstream Association, Interstate Natural Gas Association of America (INGAA), and NACE International Institute (jointly “the [...] Read More

Appendix A – Blade Report – Reliability Based Assessment of Pipeline Class Changes

Underground gas transmission pipelines are classified according to the presence of human populations in their proximity. These classifications are governed by PHMSA regulation (49 Code of Federal Regulations (CFR) Section 192.5) and industry [...] Read More

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INGAA Comments on Subpart OOOOa

Dear Docket Clerk: 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) [...] Read More

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INGAA Comments on Subpart OOOOa Appendix A

In June 2018, INGAA provided several documents to EPA regarding fugitive emissions data to substantiate its position that fugitive emissions monitoring at compressor stations should be less frequent than quarterly. EPA’s review of that [...] Read More

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INGAA Comments on Methane Policy

Dear Ms. Hambrick, The Interstate Natural Gas Association of America (INGAA), a trade association that represents members of the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States [...] Read More

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Joint Association Comments on Draft Farm Tap FAQs

The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these comments for [...] Read More

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Joint Association Comments on “Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines”

On April 16, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the Federal Register in the above captioned proceeding. In the NPRM, PHMSA proposed amendments to the Federal [...] Read More

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Joint Association Comments on PHMSA�s Automated Valve Proposed Rulemaking

The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these [...] Read More

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Joint Association Petition for Reconsideration Regarding � 192.5(d) and � 192.624(a)(1) of the Gas Transmission Rule

Introduction In accordance with 49 C.F.R. § 190.335(a), the American Gas Association (AGA), 1 American Petroleum Institute (API), 2 American Public Gas Association (APGA),3 and Interstate Natural Gas Association of America (INGAA) 4 (jointly [...] Read More

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Joint Trade Comments to DOE Regarding Resilience Standards

The American Petroleum Institute, American Gas Association, American Fuel & Petrochemical Manufacturers, the Interstate Natural Gas Association of America, and the American Public Gas Association (collectively, “Commenters”) offer the [...] Read More

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Joint Association Comments to DOT on Notice of Review of Guidance

The American Gas Association (AGA)1 , American Petroleum Institute (API)2 , American Public Gas Association (APGA)3 and Interstate Natural Gas Association of America (INGAA)4 (jointly “the Associations”) submit these comments for consideration [...] Read More

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Comments to FERC on Draft HDD Plan Guidance

Pursuant to the Environmental Staff of the Federal Energy Regulatory Commission (“FERC” or “Commission”) Office of Energy Projects’ October 26, 2018 Notice of Availability of Draft Guidance for Horizontal Directional [...] Read More

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Joint Association Comments to PHMSA Concerning Guidance on the Extension of the 7-year Integrity Management Reassessment Interval

INGAA, AGA, APGA, and API submitted these joint comments in response to PHMSA’s “Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months.” The Associations support PHMSA’s proposed [...] Read More

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Comments to FERC on Proposed Incorporation of Latest NAESB Standards

Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) August 21, 2018 Notice of Proposed Rulemaking (“NOPR”) issued in the above-referenced docket, the Interstate Natural Gas [...] Read More

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Comments to EPA Regarding Revisions to New Source Review Program

The Interstate Natural Gas Association of America (INGAA), a trade association that represents members of the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection [...] Read More

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Joint-Industry Comments to PHMSA Concerning Gas & Hazardous Liquid Pipeline Risk Models

The American Gas Association (AGA)1, American Petroleum Institute (API)2, American Public Gas Association (APGA)3, Association of Oil Pipelines (AOPL)4 and Interstate Natural Gas Association of America (INGAA)5 (jointly “the Associations”) [...] Read More

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Comments Concerning Class Location Change Requirements Advance Notice of Proposed Rulemaking

The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA) and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these comments for consideration by the [...] Read More

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Joint Association Comments on Fish and Wildlife Service’s and National Marine Fisheries Service’s Three Proposals to Revise Endangered Species Act Regulations

The ESA Cross-Industry Coalition is pleased to provide the unified position of a major portion of our nation’s economic sectors on three proposals from the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) [...] Read More

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INGAA & AGA Response to Advance Notice of Proposed Rulemaking to Revise Regulations Concerning the National Environmental Policy Act

The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the Council on Environmental Quality’s (“CEQ”) request for comment on potential [...] Read More

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Comments in Response to FERC Notice of Inquiry on Its 1999 Certificate Policy Statement

The Interstate Natural Gas Association of America (“INGAA”) submits these comments in response to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) notice of inquiry (“NOI”) on [...] Read More