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INGAA recognizes that most natural gas transmission and storage facilities are not covered by EPA’s RMP standard, as they are not considered stationary sources. Rather, natural gas transmission facilities are regulated by the U.S. [...] Read More
INGAA and its members have worked with EPA on greenhouse gas (GHG) projects dating back to the Gas Research Institute (GRI) project with EPA in the early 1990s that estimated methane emissions from natural gas systems. The GRI-EPA Reports2 remain a [...] Read More
Mr. Bruce Carlson Senior Policy Advisor, Planning and Policy Directorate U.S. Army Corps of Engineers 441 G Street, NW Washington, DC 20314 Re: Water Resources Reform and Development Act of 2014 Section 1006 – Expediting the [...] Read More
General Regulatory Approach: In the ANPRM, DHS asks “whether or not commenters think that deletions, additions or modification to the list of exempt facilities should be considered.” 79 Fed. Reg. at 48695. When it enacted the CFATS enabling [...] Read More
In the supplemental notice, OSHA is soliciting comments on whether to amend the proposed rule to require that employers inform their employees of their right to report injuries and illnesses, and that any injury and illness reporting requirements [...] Read More
On October 9, 2014, as part of an industry coalition, INGAA filed comments in response to the two proposed rules and a policy statement jointly issued by the U.S. Fish and Wildlife Service and the National Marine Fisheries Service. The [...] Read More
On September 18, 2014, Commissioner Moeller convened a meeting to consider a national electronic information and trading platform for natural gas (Docket No. AD14-19). In response to the commissioner’s invitation to submit additional [...] Read More
The Interstate Natural Gas Association of America (INGAA) submitted comments on September 29, 2014 in response to the Federal Energy Regulatory Commission’s (FERC or Commission) Notice of Proposed Rulemaking (NOPR) proposing to amend the [...] Read More
Proposed Revisions to 25 PA Code, Chapters 121 and 129, PA Bulletin, Vol. 44, No. 16 (April 19, 2014) Additional RACT Requirements for Major Sources of NOx and VOCs (Proposed Rule) Summary of Comments By the Interstate Natural Gas Association of [...] Read More
Below, please find three links to INGAA’s comments on the following white papers: Environmental Protection Agency (EPA) Methane White Paper: Oil and Natural Gas Sector Compressors Environmental Protection Agency (EPA) Methane White Paper: Oil [...] Read More
The Interstate Natural Gas Association of America (INGAA), a trade organization that advocates regulatory and legislative positions of importance to the interstate natural gas pipeline industry in North America, welcomes the opportunity to [...] Read More
Background: INGAA filed comments with the U.S. Environmental Protection Agency on April 24 on the agency’s proposed revisions to the greenhouse gas reporting rule. Since 2009, INGAA has raised significant concerns related to the [...] Read More
Several of the issues raised in OSHA’s RFI may significantly impact INGAA’s members. INGAA appreciates the opportunity to comment on OSHA’s RFI, and is willing to meet with OSHA to address any concerns OSHA may have. PSM Comments [...] Read More
Conclusion While transparency in recordkeeping serves a valuable purpose, the Proposed Rulemaking is unreasonable and unnecessarily complicated. OSHA should specify how it will utilize any data it collects. OSHA should also abandon any consideration [...] Read More
INGAA believes that OSHA’s current silica standard adequately addresses silica exposure and protects employees in the natural gas transmission industry. OSHA’s proposed standard, however, is unrealistic and imposes an [...] Read More
Annual Report: Part C Volume Transported by Transmission Lines INGAA recommends the elimination of Part C-Volume Transported by Transmission Lines. In its November 27 filing, PHMSA stated that it is requiring all gas transmission operators to submit [...] Read More
Pursuant to Section 19 of the Natural Gas Act (“NGA”) and Rule 713 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), the [...] Read More
The Interstate Natural Gas Association of America (INGAA), a trade organization that advocates regulatory and legislative positions of importance to the interstate natural gas pipeline industry in North America, welcomes the opportunity to [...] Read More
The Interstate Natural Gas Association of America (INGAA) provided comments on the International Accounting Standards Board’s (IASB) Exposure Draft, Regulatory Deferral Accounts - ED/2013/5. IASB proposed a draft interim [...] Read More