Appendix A - Blade Report - Reliability Based Assessment of Pipeline Class Changes 858KB, PDF Date Sent 12/15/2020Subject Reliability Based Assessment of Pipeline Class Changes Underground gas transmission pipelines are classified according to the presence of human populations in their proximity. These classifications are governed by PHMSA regulation (49 Code of Federal Regulations (CFR) Section 192.5) and industry standards. Operations, maintenance and integrity ... Read More
PHMSA Class Change NPRM Comments 260KB, * Date Sent 12/14/2020Subject PHMSA Class Change NPRM CommentsRecipient Agency PHMSASender Multiple Associations The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA), GPA Midstream Association, Interstate Natural Gas Association of America (INGAA), and NACE International Institute (jointly “the Associations”) submit these comments for ... Read More
Coalition Letter in Support of FERC Confirmations 121KB, PDF Date Sent 11/19/2020 Subject Coalition Letter in Support of FERC Confirmations Recipient The Honorable Mitch McConnell & The Honorable Chuck Schumer Sender Multiple Associations Dear Majority Leader McConnell and Democratic Leader Schumer: The undersigned organizations represent a broad constituency of industries, companies, and labor unions who build and provide equipment, materials, supplies, services, and human capital to energy infrastructure projects. Our broad ...
INGAA Comments on Proposal to Reissue and Modify Nationwide Permits, 85 Fed. Reg. 57,298 497KB, PDF Date Sent 11/16/2020Subject INGAA Comments on Proposal to Reissue and Modify Nationwide Permits, 85 Fed. Reg. 57,298Recipient Agency U.S. Army Corps of EngineersSender INGAA Dear Sir or Madam: On September 15, 2020, the U.S. Army Corps of Engineers (Corps) proposed to reissue the existing Nationwide Permits (NWPs), General Conditions (GCs), and definitions with some modifications, and to issue five new NWPs. See Proposal to Reissue and Modify Nationwide Permits, 85 ... Read More
Joint Association Comments on Draft Farm Tap FAQs 418KB, PDF Date Sent 06/19/2020Subject Joint Association Comments on Draft Farm Tap FAQsRecipient Agency PHMSASender AGA, API, APGA, & INGAA Pipeline safety is the top priority of the Associations and our members. The Associations support PHMSA’s efforts to provide clarity regarding the pipeline safety requirements applicable to individual service lines directly connected to transmission pipelines, commonly referred to as “farm taps.” The Associations’ comments only address gas transmission and distribution pipeline considerations affected by the draft FAQs... Read More
Joint Association Comments on "Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines" 328KB, PDF Date Sent 06/15/2020Subject Joint Association Comments on PHMSA's “Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines”Recipient Agency PHMSASender API, AOPL, AFPM, INGAA, AGA, APGA, GPA Midstream, & LNG Allies, The US LNG Association On April 16, 2020, the Pipeline and Hazardous Materials Safety Administration (PHMSA) published a notice of proposed rulemaking (NPRM) in the Federal Register in the above captioned proceeding.1 In the NPRM, PHMSA proposed amendments to the Federal Pipeline Safety Regulations for the safety of hazardous liquid pipelines that would revise the requirements for... Read More
Joint Association Comments on PHMSA’s Automated Valve Proposed Rulemaking 666KB, PDF Date Sent 04/06/2020Subject Joint Association Comments on PHMSA’s Automated Valve Proposed RulemakingRecipient Agency PHMSASender 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 ... Read More
INGAA Comments on CEQ NEPA Regulations 825KB, PDF Date Sent 03/10/2020Subject INGAA Comments on CEQ NEPA Regulations Recipient Agency Mr. Edward Boling, Council on Environmental QualitySender INGAA The Interstate Natural Gas Association of America (“INGAA”) respectfully submits these comments in response to the Council on Environmental Quality’s (“CEQ”) request for comment on revisions to its regulations concerning the National Environmental Policy Act ... Read More
Natural Gas Coalition Letter to Members of the Subcommittee on Energy 1MB, PDF Date Sent 02/03/2020 Subject Natural Gas Coalition Letter to Members of the Subcommittee on Energy Recipient Subcommittee on Energy, Committee on Energy & Commerce Sender Natural Gas Coalition Dear Members of the Subcommittee on Energy: As organizations representing the natural gas value chain, we are writing to express our support for sound federal policy that facilitates the continued development of natural gas infrastructure. Energy is the capacity to do work. Without it, ...
INGAA Comments on Methane Policy 143KB, PDF Date Sent 11/25/2019Subject Comments on Methane PolicyRecipient Agency Ms. Amy HambrickSender INGAA Dear Ms. Hambrick, 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) request ... Read More
Joint Association Petition for Reconsideration Regarding § 192.5(d) and § 192.624(a)(1) of the Gas Transmission Rule 276KB, PDF Date Sent 10/31/2019Subject Joint Association Petition for Reconsideration Regarding § 192.5(d) and § 192.624(a)(1) of the Gas Transmission RuleRecipient Agency PHMSASender AGA, API, APGA, & INGAA Introduction In accordance with 49 C.F.R. § 190.335(a), the American Gas Association (AGA), 1 American Petroleum Institute (API), 2 American Public Gas Association (APGA), 3 and Interstate Natural Gas Association of America (INGAA) 4 (jointly “the Associations”) ... Read More
Joint Trade Comments to DOE Regarding Resilience Standards 1MB, PDF Date Sent 08/23/2019Subject Joint Trade Comments to DOE Regarding Resilience StandardsRecipient Agency DOESender API, AGA, AFPM, APGA, INGAA The American Petroleum Institute, American Gas Association, American Fuel & Petrochemical Manufacturers, the Interstate Natural Gas Association of America, and the American Public Gas Association (collectively, “Commenters”) offer the following comments on the Department of ... Read More
Joint Association Letter in Support of Pipeline Safety Advisory Committees 122KB, PDF Date Sent 07/17/2019 Subject Joint Association Letter in Support of Pipeline Safety Advisory Committees Recipient The Honorable Elaine L. Chao Sender Multiple Associations Secretary Chao: Our organizations write to express support for the Department of Transportation’s Technical Pipeline Safety Standards Committee and Technical Hazardous Liquid Pipeline Safety Standards Committee – also known as the Gas Pipeline Advisory Committee (GPAC) and Liquid ...
Joint Association Comments to DOT on Notice of Review of Guidance 324KB, PDF Date Sent 05/08/2019Subject RESPONSE TO NOTICE OF REVIEW OF GUIDANCE Recipient Agency DOTSender AGA, API, APGA, and INGAA The American Gas Association (AGA) 1 , American Petroleum Institute (API) 2 , American Public Gas Association (APGA) 3 and Interstate Natural Gas Association of America (INGAA) 4 (jointly “the Associations”) submit these comments for consideration by the Department of ... Read More
INGAA Written Statement on Reauthorization of the Pipeline Safety Act Before House Energy and Commerce Subcommittee on Energy 400KB, PDF Date Sent 04/29/2019 Subject INGAA Written Statement on Reauthorization of the Pipeline Safety Act Before House Subcommittee on Energy Dear Chairman Rush, Ranking Member Upton, and Members of the Subcommittee: The Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to submit this testimony regarding the 2019 reauthorization of the Pipeline Safety Act. INGAA is a trade association that ... Read More
Paul Amato Testifies Before the Senate Subcommittee on Transportation and Safety Regarding Reauthorization of the Pipeline Safety Act 453KB, PDF Date Sent 04/10/2019 Subject Paul Amato Testifies Before the Senate Subcommittee on Transportation and Safety Re: Pipeline Safety Reauthorization Chairman Fischer, Ranking Member Duckworth, and Members of the Subcommittee: Good morning. My name is Paul Amato, and I am Vice President, Engineering, Operations, and Environmental, Health & Safety at Iroquois Pipeline Operating Company. Iroquois Gas Transmission System, L.P., through ... Read More
INGAA Written Statement on Reauthorization of Pipeline Safety Act Before House Transportation & Infrastructure Subcommittee on Railroads, Pipelines, and Hazardous Materials 355KB, PDF Date Sent 04/02/2019 Subject INGAA Written Statement on Reauthorization of Pipeline Safety Act Before House Transportation & Infrastructure Subcommittee Chairman Lipinski, Ranking Member Crawford, and Members of the Subcommittee: The Interstate Natural Gas Association of America (INGAA) is a trade association that represents the interstate natural gas pipeline industry. INGAA’s members transport the vast majority of the natural gas ... Read More
Donald F. Santa Testifies at FERC "Security Investments for Infrastructure" Technical Conference 129KB, PDF Date Sent 03/28/2019 Subject Donald F. Santa Testifies at FERC "Security Investments for Infrastructure" Technical Conference Good morning, the Interstate Natural Gas Association of America (INGAA) appreciates the opportunity to address the Commission and senior officials of the Department of Energy on the important topic of current cyber and physical security practices to protect energy infrastructure. My comments on ... Read More
Multi-Group Letter to DOT Secretary Chao in Support of PHMSA Gas Transmission Rule 166KB, PDF Date Sent 02/07/2019 Subject Multi-Group Letter to DOT Secretary Chao in Support of PHMSA Gas Transmission Rule Recipient The Honorable Elaine L. Chao Sender AGA, APGA, API, INGAA, PSC, & PST Secretary Chao: Our organizations write to express support for the Department of Transportation’s pending gas transmission pipeline safety rule. As public safety advocates and representatives of natural gas transmission pipeline companies, we encourage you to act expeditiously ...
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