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INGAA Comments on FERC’s Income Tax Notice of Inquiry

   INGAA’s comments respond to the Commission’s NOI that was initiated as a result of the court’s holding in United Airlines, Inc. v. FERC that, “if FERC elects to impute partner taxes to the partnership pipeline [...] Read More

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Underground Natural Gas Storage Interim Final Rule Comments

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) jointly submit these comments on the Pipeline and [...] Read More

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INGAA�s Response to EPA�s Proposed Revisions to the Prevention of Significant Deterioration and Title V Permitting Regulations for Greenhouse Gases (GHG) and Establishment of a GHG Significant Emission Rates

 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) proposed rule, [...] Read More

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Comments of the Interstate Natural Gas Association of America on Interim Final Rule

INGAA filed comments on the Pipeline and Hazardous Materials Safety Administration’s (“PHMSA”) interim final rule (“IFR”) concerning Enhanced Emergency Order Procedures, on December 13.  PHMSA issued the IFR in [...] Read More

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Comments on September 22

 The American Gas Association (“AGA”) and the Interstate Natural Gas Association of America (“INGAA”) submits these comments on the Department of the Interior’s (“DOI”) proposed regulations concerning Appraisals and Valuations of [...] Read More

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INGAA�s Response to EPA�s Information Collection Request for Oil and Gas Facilities Submitted to OMB for Review and Approval

   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) notice, [...] Read More

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INGAA’s Comments on the Discussion Draft of Underground Gas Storage Regulations

The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to submit these comments in response to the Division of Oil, Gas, and Geothermal Resources (DOGGR) “Discussion Draft Underground Gas Storage Regulations” [...] Read More

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INGAA CEII Comments

Pursuant to the Notice of Proposed Rulemaking (NOPR) issued June 16, 2016 by the Federal Energy Regulatory Commission (Commission) in the above-referenced proceeding,[1] the Interstate Natural Gas Association of America (INGAA) respectfully submits [...] Read More

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INGAA Comments on EPA Oil and Gas ICR Review

  The Interstate Natural Gas Association of America (INGAA) respectfully submits these comments in response to the EPA Notice, “Proposed Information Collection Request; Comment Request; Information Collection Effort for Oil and Gas [...] Read More

INGAA Comments on Proposal to Reissue and Modify Nationwide Permits

On June 1, 2016, the U.S. Army Corps of Engineers (“Corps”) proposed to reissue the existing nationwide permits (“NWPs”), general conditions, and definitions with some modifications. See Proposal to Reissue and [...] Read More

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Pipeline Safety: Request for Revision of a Previously Approved Information Collection National Pipeline Mapping System Program

INGAA appreciates the opportunity to provide comments on proposed revisions to the National Pipeline Mapping System (NPMS) data collection program and associated Operator Standards Manual (OSM) included in this Docket. INGAA provided comments to [...] Read More

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Constitution amicus brief

UNOPPOSED MOTION FOR LEAVE TO FILE AMICUS CURIAE BRIEF IN SUPPORT OF PETITIONER The National Association of Manufacturers, Chamber of Commerce of the United States of America, Interstate Natural Gas Association of America, American Gas [...] Read More

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INGAA’s Comments on the CARB Proposed Regulation for Greenhouse Gas Emission Standards for Oil and Natural Gas Facilities

The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to submit these comments in response to the California Air Resources Board (ARB) proposed rule, “Greenhouse Gas Emission Standards for Crude Oil and Natural Gas [...] Read More

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Pipeline Safety: Information Collection Activities: Agency Information Collection Activities; Proposals

INGAA appreciates the opportunity to provide comments on proposed revisions to the incident and accident report forms and associated instructions included in this Docket. INGAA collaborated with PHMSA on early versions of these revisions. INGAA [...] Read More

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Pipeline Safety: Safety of Gas Transmission and Gathering Pipelines

The Interstate Natural Gas Association of America (INGAA) offers these comments on the Notice of Proposed Rulemaking (NPRM) issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) on April 8, 2016. INGAA is a trade association [...] Read More

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INGAA Amicus Brief

UNOPPOSED MOTION OF THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA FOR LEAVE TO FILE AMICUS CURIAE BRIEF IN SUPPORT OF DEFENDANTS The Interstate Natural Gas Association of America (“INGAA”) respectfully moves under Local Civil Rule 7(o) for [...] Read More

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INGAA responds to EPA’s request for information for the Natural Gas Transmission and Storage NESHAP (40 CFR

In November 2011, INGAA commented on proposed amendments. In response to final Subpart HHH amendments published in August 2012, INGAA submitted a request for reconsideration in September 2012. INGAA understands that EPA likely will amend Subpart HHH [...] Read More

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INGAA Comments on EPA Proposed Revisions to Test Methods

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) proposed rulemaking [...] Read More

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INGAA comments on EPA’s proposed revisions to the Greenhouse Gas Reporting Rule for Leak Detection Methodology

Summary of INGAA Comments 1. INGAA supports consistency between different regulatory programs in order to reduce redundancies and allow for consistent use of measurement techniques and reporting. 2. This Proposed Rule is premature since it [...] Read More

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Gas Transmission NPRM: Request for Extension

INGAA, together with the American Gas Association, the American Petroleum Institute, the American Public Gas Association, the Gas Processors Association and the Independent Petroleum Association of America filed March 25 with PHMSA for a 60-day [...] Read More