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INGAA appreciates PHMSA’s interest in improving its incident, infrastructure and performance database.  Consistent with this focus, the proposed definition of “incident” should be substantially modified to reflect the central role that risk plays in distinguishing incidents from other events.  INGAA urges a number of revisions, and specifically objects to the… Read More

INGAA’s members and the Services have a mutual interest in improving the efficiency of the conference and consultation processes implementing section 7 of the Endangered Species Act (“ESA”).  For interstate pipelines, improved efficiency speeds the ESA consultation process and makes it more predictable and less costly.  For the Services, improved… Read More

This INGAA Foundation report forecasts the most critical skills for the natural gas pipeline industry workforce.  By identifying positions that are expected to be in short supply and critical functions in the design, construction, operation and maintenance of pipelines, this study locates the highest risk "intersections" of workforce and tasks… Read More

The following letter is Don Santa’s response to Jeff Wiese’s letter denoting construction conerns and outlining PHMSA’s reaction to INGAA’s action plan regarding pipe quality.  This letter has been shared with the INGAA Board of Directors, the Foundation Board of Directors, and various INGAA committees. Read More

The increased use of natural gas in homes and businesses (“direct use”) is a form of energy efficiency which will make an important contribution in assisting many states and the nation in attaining energy efficiency and carbon reduction targets. States should be encouraged to include increased direct use of natural… Read More

NGC understands EPA’s goal in developing the Proposed Rule is to obtain data of sufficient quality to support climate change policies and regulations, while at the same time minimizing the Proposed Rule’s administrative burdens – both by excluding small emitters and by crafting requirements that are consistent with existing greenhouse… Read More

EPA proposed a rule for the mandatory reporting of greenhouse gases (hereinafter referred to as the GHG Reporting Rule) in the Federal Register on April 10, 2009. The GHG Reporting Rule revises a number of mobile source rules in Title 40 of the Code of Federal Regulations (40 CFR) and stationary… Read More

  Objective of the Gas Interchangeability Report The objective of this white paper is to define acceptable ranges of natural gas characteristics that can be consumed by end users while maintaining safety, reliability, and environmental performance. It is important to recognize that this objective applies equally to imported LNG and… Read More

The Interstate Natural Gas Association of America (INGAA), submits comments on the U.S. EPA’s proposed rule National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Reciprocating Internal Combustion Engines (RICE), hereinafter referred to as the “Proposed Rule”. The proposal, which would revise 40 CFR Part 63, Subpart ZZZZ, was published in… Read More

The attached letter to House and Senate tax writing committees asks that they consider extending the bonus depreciation for capital expenditures contained in recent stimulus legislation, for those projects like pipelines that have longer construction and approval lead times. Read More

With all of the amendments and changes to the SPCC rule, the regulated community is placed in a race against time to comply, assuming the current 2009 implementation dates are not extended. The amendments have significantly altered many elements of the 2002 SPCC rule, which will require fiscal planning and… Read More

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… Read More

This study focuses on the pipeline infrastructure requirements for carbon capture and sequestration (CCS) in connection with compliance with mandatory greenhouse gas emissions reductions. The major conclusion of the study is that while CCS technologies are relatively well defined, there remain technological challenges in the carbon capture and sequestration phases,… Read More

INGAA sent a letter to Senator Harry Reid, the Majority Leader of the Senate, regarding energy infrastructure development and interstate natural gas pipelines.  The letter was sent to coincide with the National Clean Energy Project: Building the New Economy forum that was held in Washington, February 23, 2009, and… Read More

INGAA sent a letter to Senator Harry Reid, the Majority Leader of the Senate, regarding energy infrastructure development and interstate natural gas pipelines.  The letter was sent to coincide with the National Clean Energy Project: Building the New Economy forum that was held in Washington, February 23, 2009, and co-sponsored… Read More

  INGAA members operate equipment that requires continuous parameter monitoring systems (CPMS) for compliance assurance.  The proposed requirements in 40 CFR 60, Appendix B, Performance Specification 17 (PS 17) and 40 CFR 60, Appendix F, Procedure 4 (Procedure 4) will affect INGAA member operations.  INGAA comments discuss our concern that… Read More

2008 INGAA Foundation Survey results are now available. Read More

These guidelines were developed using a consensus process by a work group formed by Foundation members. The guidelines draw upon the experience and leading practices of the full breadth of INGAA Foundation members as well as practices used throughout the industry, including the Common Ground Alliance (CGA) Best Practices and… Read More