Comments to FERC on Draft HDD Plan Guidance 180KB, PDF Date Sent 12/28/2018Recipient Agency FERCSender INGAA Pursuant to the Environmental Staff of the Federal Energy Regulatory Commission (“FERC” or “Commission”) Office of Energy Projects’ October 26, 2018 Notice of Availability of Draft Guidance for Horizontal Directional Drill Monitoring, Inadvertent Return Response, and ... Read More
Joint Association Comments to PHMSA Concerning Guidance on the Extension of the 7-year Integrity Management Reassessment Interval 256KB, PDF Date Sent 12/17/2018Subject Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 MonthsRecipient Agency PHMSASender AGA, API, APGA, and INGAA INGAA, AGA, APGA, and API submitted these joint comments in response to PHMSA’s “Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months.” The Associations support PHMSA’s proposed FAQs. In the comments, the Associations ... Read More
Comments to EPA Regarding Revisions to New Source Review Program 264KB, PDF Date Sent 10/30/2018Recipient Agency EPASender INGAA The Interstate Natural Gas Association of America (INGAA), a trade association that represents members of the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection Agency’s (EPA’s) request for input on ... Read More
Joint-Industry Comments to PHMSA Concerning Gas & Hazardous Liquid Pipeline Risk Models 619KB, PDF Date Sent 10/17/2018Recipient Agency PHMSASender AGA, AOPL, API, APGA & INGAA The American Gas Association (AGA)1, American Petroleum Institute (API)2, American Public Gas Association (APGA)3, Association of Oil Pipelines (AOPL)4 and Interstate Natural Gas Association of America (INGAA)5 (jointly “the Associations”) submit these comments on the Pipeline and ... Read More
Comments Concerning Class Location Change Requirements Advance Notice of Proposed Rulemaking 644KB, PDF Date Sent 10/01/2018Recipient Agency PHMSASender INGAA, AGA, API, APGA 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”) submit these comments for consideration by the Pipeline and Hazardous Materials Safety ... Read More
Letter from members of Congress to PHMSA Administrator Elliott in support of updating class location change regulations 135KB, PDF Date Sent 10/01/2018 Recipient PHMSA Administrator Howard "Skip" Elliott Sender Rep. Denham, Rep. Gallagher, Rep Gibbs, Rep. Graves, Sen. Inhofe, Rep Rokita Dear Administrator Elliott, We are writing to you regarding the Pipeline and Hazardous Materials Safety Administration's (PHMSA) proposed rulemaking to conform the outdated class location change regulations with PHMSA's modem integrity management regulations. We support updating this ...
Comments to FERC on Proposed Incorporation of Latest NAESB Standards 310KB, PDF Date Sent 10/01/2018Recipient Agency FERCSender INGAA Pursuant to the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) August 21, 2018 Notice of Proposed Rulemaking (“NOPR”) issued in the above-referenced docket, the Interstate Natural Gas Association of America (“INGAA”) ... Read More
Joint Association Comments on Fish and Wildlife Service's and National Marine Fisheries Service's Three Proposals to Revise Endangered Species Act Regulations 936KB, PDF Date Sent 09/24/2018Recipient Agency U.S. Fish and Wildlife Service, National Marine Fisheries ServiceSender INGAA & 8 Other Associations The ESA Cross-Industry Coalition is pleased to provide the unified position of a major portion of our nation’s economic sectors on three proposals from the U.S. Fish and Wildlife Service (FWS) and the National Marine Fisheries Service (NMFS) (together, the Services) to amend their Endangered ... Read More
INGAA & AGA Response to Advance Notice of Proposed Rulemaking to Revise Regulations Concerning the National Environmental Policy Act 507KB, PDF Date Sent 08/20/2018Recipient Agency Mr. Edward Boling, Council on Environmental QualitySender INGAA, AGA The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the Council on Environmental Quality’s (“CEQ”) request for comment on potential revisions to its ... Read More
Comments in Response to FERC Notice of Inquiry on Its 1999 Certificate Policy Statement 1MB, PDF Date Sent 07/25/2018Recipient Agency FERCSender INGAA The Interstate Natural Gas Association of America (“INGAA”) submits these comments in response to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) notice of inquiry (“NOI”) on its currently effective policy statement1 on the ... Read More
Chad Zamarin before the House Subcommittee on Railroads, Pipelines & Hazardous Materials Regarding Pipeline Safety Oversight 111KB, PDF Date Sent 06/21/2018 Good morning. My name is Chad Zamarin, and I am Senior Vice President of Corporate Strategic Development at the Williams Companies. Williams owns and operates natural gas gathering, processing and transmission infrastructure, including the nation’s largest-by-volume natural gas interstate ... Read More
Comments on Pipeline Safety: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments 2MB, PDF Date Sent 06/06/2018Sender AGA, API, APGA & INGAA 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”) submit these comments for consideration by the Pipeline and Hazardous ... Read More
Answer to Notice of Inquiry on Accumulated Deferred Income Taxes 275KB, PDF Date Sent 06/05/2018Recipient Agency FERCSender INGAA INGAA responds to the argument made by commenters that the elimination of a tax allowance for MLPs and potentially other pass-through entities must result in the expeditious return of excess ADIT to customers of such pipelines. For the reasons stated in INGAA’s comments, ADIT issues ... Read More
Mountain Valley Pipeline and Atlantic Coast Pipeline Projects State Water Control Board Request for Technical Information on Specific Wetland and/or Stream Crossings 163KB, PDF Date Sent 05/30/2018 Recipient Virginia Department of Environmental Quality Sender INGAA Dear Agency Officials: The Interstate Natural Gas Association of America (“INGAA”) welcomes this opportunity to provide technical comments and information to the Virginia Department of Environmental Quality (“DEQ”) on the Mountain Valley Pipeline ...
Supplemental Joint Comments on the Safety of Underground Natural Gas Storage Facilities Interim Final Rule 390KB, PDF Date Sent 05/25/2018Sender AGA, API, INGAA On February 17, 2017, November 20, 2017 and March 2, 2018, the Associations, along with the American Public Gas Association, filed comments relating to PHMSA’s Pipeline Safety: Safety of Underground Natural Gas Storage Facilities Interim Final Rule (Docket No. PHMSA-2016-0016). The ... Read More
INGAA Comments on ADIT Notice of Inquiry 385KB, PDF Date Sent 05/21/2018Recipient Agency FERCSender INGAA On December 22, 2017, the President signed the Tax Cut and Jobs Act (“TCJA”) into law, which reduced the federal corporate income tax rate from 35 percent to 21 percent, effective January 1, 2018. Additionally, as pertinent to these comments, the TCJA prohibited the use of bonus ... Read More
INGAA Comments on EPA’s ICR Regarding the Voluntary Natural Gas STAR Methane Challenge Program 223KB, PDF Date Sent 05/14/2018Recipient Agency EPASender INGAA Dear Mr. Pryor, The Interstate Natural Gas Association of America (“INGAA”) respectfully submits these comments in response to the U.S. Environmental Protection Agency’s (“EPA’s”) request for comments on the Information Collection Request (“ICR”) ... Read More
INGAA Answer in Notice of Proposed Rulemaking on Rate Changes Relating to the Federal Income Tax Rate 342KB, PDF Date Sent 05/10/2018Recipient Agency FERCSender INGAA A few commenters request the Commission to clarify that negotiated rate contracts are subject to revision and allow rate reductions for shippers under such contracts. Indicated Shippers argue that the Commission should allow negotiated rate shippers to share in the tax cost reductions ... Read More
Joint Petition for Rulemaking on Pressure Relief Device (PRD) Testing Requirements 197KB, PDF Date Sent 05/10/2018Recipient Agency PHMSASender AGA, INGAA AGA and INGAA are petitioning PHMSA to amend 49 CFR Part 193.2619 to recognize and enforce the pressure relief device (PRD) testing requirements in NFPA 59A (2001 edition) at 11.5.5.1(e) (incorporated by reference in 49 CFR Part 193) instead of the current requirements in 49 CFR Part ... Read More
INGAA Reply Comments on Grid Resilience in RTOs/ISOs 530KB, PDF Date Sent 05/09/2018Recipient Agency FERCSender INGAA INGAA supports the Commission’s continued examination of grid reliability and resilience in regional transmission organizations (“RTOs”) and independent system operators (“ISOs”). Every RTO and ISO, including PJM, plays a crucial role in ensuring a reliable ... Read More