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INGAA submits comments and filings to various regulatory, congressional and administrative entities.  You can search by year, agency, and title using the search engine below.  Also, the most recent submissions are highlighted on the home page and appear in chronological order below the search engine.

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  • INGAA's Written Comments to PCB ANPRM

    Submitted: 08/20/2010

     INGAA’s comments to the EPA’s ANPRM are in large part founded on the collective experience, knowledge, and expertise of its constituent members. Altogether, INGAA’s membership represents many decades of practical, hands-on experience dealing with those isolated segments of the interstate natural gas transmission system that were impacted by PCBs. While there is well-settled information in the public domain ...  More>>

  • INGAA Letter Comment re FEMA's Proposed PS-Prep Standards

    Submitted: 01/15/2010

    On January 15, 2010, the Interstate Natural Gas Association of America (“INGAA”) sent a comment letter to the Federal Emergency Management Agency (“FEMA”) addressing FEMA’s proposed adoption of three privately developed standards for assessing emergency preparedness.  The standards would be used as part of FEMA’s Voluntary Private Sector Accreditation and Certification Preparedness Program (commonly ...  More>>

  • Prevention of Significant Deterioration (PSD) and Title V Permits Issued Under the Clean Air Act (CAA)

    Submitted: 12/23/2009

    The Interstate Natural Gas Association of America (“INGAA) submits these comments regarding the EPA proposed “Tailoring Rule”. Under the Proposed Rule, greenhouse gas (“GHG”) emissions by some stationary sources would be regulated through Prevention of Significant Deterioration (“PSD”) and Title V permits issued under the Clean Air Act (“CAA”).  A new stationary source would be ...  More>>

  • Pipeline Safety: Pipeline Damage Prevention Programs Filing

    Submitted: 12/14/2009

    On December 14, 2009 INGAA filed a letter of support and comments to docket number PHMSA-2009-0192 regarding Pipeline Safety: Pipeline Damage Prevention Programs.  INGAA is in support of PHMSA's effort to improve One Call enforcement.  More>>

  • Prevention of Significant Deterioration (PSD): Reconsideration of Interpretation of Regulations that Determine Pollutants Covered by the Federal PSD Permit Program

    Submitted: 12/07/2009

    INGAA submits this comment letter pursuant to the notice issued by the Environmental Protection Agency (“EPA”) on September 30, 2009, and published in the Federal Register on October 7, 2009, (the “Reconsideration Notice”). [1]   We write because it is imperative EPA establish that to the extent greenhouse gas (GHG) regulation under the light-duty vehicle rule (the “Mobile Rule”) [2] ...  More>>

  • Allowance for Funds Used During Construction INGAA Motion to Interevene and Request for Rehearing 9-28-09

    Submitted: 09/28/2009

      INGAA seeks rehearing of the Commission’s order of August 27, 2009, in Southern Natural Gas Co., et al ., 128 FERC ¶ 61,198 (“Order Granting Abandonment Authority and Issuing Certificates”) and its order of September 4, 2009 in Ruby Pipeline, LLC, 128 FERC ¶ 61,224 (“Preliminary Determination On Non-Environmental Issues”).   INGAA aruges that, pursuant to Rule ...  More>>

  • TSA Pipeline Operator Security Information Comments

    Submitted: 09/28/2009

    On September 28, 2009, INGAA filed comments addressing the Transportation Security Administration’s proposal to solicit contact information and establish a voluntary incident reporting program as part of it forthcoming Pipeline Security Guidelines.  INGAA does not oppose TSA collecting contact information for pipeline security managers.  INGAA raises four objections to TSA’s incident reporting proposal:  (1) the ...  More>>

  • PHMSA "Standards Barrel" Filing

    Submitted: 09/23/2009

    INGAA supports the proposed incorporation of updated consensus standards into 49 C.F.R. Part 192 (“Part 192”).  INGAA and its members participate in many of the committees responsible for developing these standards, and INGAA recognizes that the value of the consensus process cannot be fully realized until the results of that process, revised and improved technical standards, are incorporated into PHMSA’s ...  More>>

  • INGAA Comments to U.S. EPA proposed Rule, National Ambient Air Quality Standards for Nitrogen Dioxide (2009)

    Submitted: 09/14/2009

    INGAA is concerned that the NO 2 NAAQS Proposal could result in onerous regulatory requirements for NOx sources throughout the U.S. , without commensurate societal benefit or compelling evidence that the proposed 1-hour standard is necessary to protect public health and welfare.   In addition, NO 2 will continue to decrease as NOx control programs are implemented to address nonattainment with the ozone and PM 2.5 NAAQS.   ...  More>>

  • NAESB Standards INGAA Comments 9-08-09

    Submitted: 09/08/2009

    INGAA supports the Commission's proposal to adopt NAESB standards for index-based pricing of capacity releases and flexible receipt and delivery points in accordance with the foregoing comments, and respectfully requests that the Commission defer implementation of final standards for index pricing of releases and flexible points until an appropriate time after it issues an order adopting NAESB WGQ Version 1.9.   More>>

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