Environment

INGAA�s comments to EPA�s Proposed Rule on Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan Requirements

U.S. Environmental Protection Agency
Air and Radiation Docket and Information Center
Mailcode: 28221T
1200 Pennsylvania Avenue, N.W.
Washington, D.C. 20460
 
Re: “Fine Particulate Matter National Ambient Air Quality Standards: State Implementation Plan
Requirements,” Proposed Rule (Docket No. EPA–HQ–OAR–2013–0691)
 
To Whom It May Concern:
 
The Interstate Natural Gas Association of America (INGAA) submits these comments to address the
Environmental Protection Agency (EPA)’s Proposed Rule on Fine Particulate Matter National Ambient
Air Quality Standards (Proposed Rule).1 INGAA’s 24 members represent the vast majority of the
interstate natural gas transmission pipeline companies in the United States, operating approximately
200,000 miles of pipelines and serving as an indispensable link between natural gas producers and
consumers.
 
As part of the Proposed Rule issued on March 23, 2015, EPA raised a question about what other factors,
such as volatility, might constitute a precursor to the formation of fine particulate matter (PM 2.5). EPA
presumed that direct PM 2.5 and PM 2.5 precursors such as volatile organic compounds (VOCs) and
ammonia would be regulated. Historically, EPA has excluded methane from the definition of a VOC.2
INGAA continues to support this position. Methane is not a precursor to PM 2.5. INGAA also asserts that
states would not have the additional regulatory authority to regulate methane as a precursor to PM 2.5.