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INGAA raises concerns with FEMA’s Floodplain Management Guidelines

The Interstate Natural Gas Association of America (INGAA), a trade association that advocates regulatory and legislative positions of importance to the interstate natural gas transmission pipeline industry in North America, respectfully submits [...] Read More

INGAA Comments on FAA’s Unmanned Aircraft Systems Proposal

The Interstate Natural Gas Association of America (INGAA), a trade association that advocates regulatory and legislative positions of importance to the interstate natural gas transmission pipeline industry in North America, respectfully submits [...] Read More

INGAA supports the proposed change of EPA’s rule: “Definitions of Low Pressure Gas Well and Storage Vessel Standards of Performance for New Stationary Sources.”

The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments regarding the proposed amendments to the new source performance standards (NSPS) for [...] Read More

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INGAA Submits Comments on EPA’s Draft GHG Report

  INGAA believes EPA clearly and transparently should explain all changes to the methodology it relies upon to arrive at its National Inventory. All stakeholders should have the ability to understand the reason for any increases or decreases to [...] Read More

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NGC urges FERC to hold fuel assurance technical conferences

Dear Chairman LaFleur: The Natural Gas Council, and other entities representing the natural gas value chain, submit these comments in response to the fuel assurance reports Independent System Operators and Regional Transmission Organizations filed [...] Read More

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Natural Gas Council urges CEQ to withdraw draft guidance on considering greenhouse gas emissions in NEPA reviews

The Natural Gas Council submitted comments in response to the Council on Environmental Quality’s (CEQ) “Revised Draft Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in [...] Read More

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INGAA encourages CEQ to withdraw draft guidance on including greenhouse gas emissions in NEPA reviews

INGAA filed comments on March 25, 2015 on the Council on Environmental Quality’s (CEQ) “Revised Draft Guidance for Federal Departments and Agencies on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in NEPA [...] Read More

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INGAA recommends that the EPA does not adopt more stringent Ozone regulations.

INGAA recommends that the EPA retain the current 75 part per billion (ppb) ozone NAAQS rather than pursue a more stringent standard. In addressing its concerns, INGAA raises the following specific issues: (1) ambient ozone levels are declining and [...] Read More

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INGAA supports categorizing the northern long-eared bat species as threatened

On March 17, INGAA filed comments in response to the U.S. Fish & Wildlife Service (USFWS)’s proposed rule requesting comment on whether the northern long-eared bat (NLEB) should be listed as threatened, endangered, or does not warrant listing. [...] Read More

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INGAA comments on FERC’s Cost Recovery Mechanisms for Modernization of Natural Gas Facilities

Pursuant to the schedule established in the Federal Energy Regulatory Commission’s Proposed Policy Statement,1 the Interstate Natural Gas Association of America (“INGAA”) submits its comments in reply to various comments submitted [...] Read More

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INGAA Comments on EPA Proposed Rule

The Interstate Natural Gas Association of America (INGAA) respectfully submits these comments in response to the “Greenhouse Gas Reporting Rule: 2015 Revisions and Confidentiality Determinations for Petroleum and Natural Gas Systems” [...] Read More

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Natural Gas Council comments on RTO/ISO Data Request Submissions to FERC

The RTO/ISO responses clearly confirm that there is not a nationwide problem during the morning electric ramp associated with the current start time of the Gas Day.   Moreover, no RTO or ISO has shown a causal link between generator de-rate [...] Read More

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INGAA comments on International Accounting Standards Board’s (IASB’s) September 2014 Discussion Paper

The Interstate Natural Gas Association of America (INGAA) welcomes the opportunity to provide comments in response to the International Accounting Standards Board’s (IASB’s) September 2014 Discussion Paper, Reporting the Financial Effects of [...] Read More

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INGAA comments on FERC proposed policy statement on cost recovery mechanisms for modernization of natural gas facilities

INGAA appreciates FERC's flexible approach towards recovery of prudently incurred costs associated with modernizing pipeline infrastructure and complying with governmental regulations requiring the inspection, maintenance and replacement of certain [...] Read More

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INGAA comments on BLM’s proposed rule with major Oil and Gas Industry associations

INGAA, The American Petroleum Institute (API), The Association of Oil Pipe Lines (AOPL) and The Independent Petroleum Association of America (IPAA) are collectively concerned about the limited opportunity BLM provided oil and gas stakeholders to [...] Read More

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INGAA Comments on BIA’s Proposed Rule on Rights-of-Way on Indian Land

INGAA appreciates BIA’s efforts to streamline the application, approval, renewal, and regulatory process for rights-of-way over Indian lands. As it currently exists, pipeline permitting is a protracted and decentralized process, and this is [...] Read More

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INGAA comments on PHMSA’s Request for Revision of a Previously Approved Information Collection – National Pipeline Mapping System Program

INGAA supports PHMSA's desire to improve its National Pipeline Mapping System (NPMS) and make certain information more accessible to first responders and members of the public. However, INGAA has significant concerns with the scope and content of [...] Read More

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INGAA comments on EPA’s Clean Power Rule

INGAA is confident that, subject to certain caveats and assuming that certain preconditions can be satisfied, the interstate natural gas pipeline industry can respond to demand for the natural gas pipeline capacity that may be necessary to enable [...] Read More

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INGAA Files Comments to FERC on Gas Day

INGAA strongly supports the proposed modifications to the gas scheduling timeline developed by the North American Energy Standards Board (NAESB), as set forth in the filing submitted by NAESB on September 29, 2014, in this proceeding. This revised [...] Read More

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Comments of the Waters Advocacy Coalition on the Environmental Protection Agency�s and U.S. Army Corps of Engineers� Proposed Rule to Define �Waters of the United States� Under the Clean Water Act EPA-HQ-OW-2011-0880

Deidre G. Duncan Virginia S. Albrecht Kerry L. McGrath Hunton & Williams LLP 2200 Pennsylvania Avenue, NW Washington, DC 20037 (202) 955-1500 Counsel for Coalition   November 13, 2014   The Waters Advocacy Coalition (“WAC” [...] Read More