Filings, Letters and Testimonies

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.

Filing Topics
  • Congress 7
  • Construction 5
  • Economics 11
  • Environment 24
  • Executive Branch 2
  • Regulatory 42
  • Safety 19
  • Security 1
Type
  • Filing 318
  • Letter 48
  • Testimony 23
Agency
  • Administration 0
  • BLM 1
  • Bureau of Indian Affairs 3
  • CARB 1
  • CEQ 4
  • CFTC 2
  • Congress 2
  • CorpsEngineers 6
  • DHS 1
  • DOE 2
  • DOGGR 1
  • DOI 4
  • DOT 7
  • EPA 68
  • FAA 0
  • FEMA 1
  • FERC 144
  • IASB 3
  • NOAA 2
  • NTSB 1
  • NYSDEC 1
  • OSHA 5
  • PHMSA 47
  • USDC 1
  • USFWS 6
Date
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  • 418KB, PDF
    06/19/2020
    Joint Association Comments on Draft Farm Tap FAQs
    PHMSA
    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...
  • 328KB, PDF
    06/15/2020
    Joint Association Comments on PHMSA's “Pipeline Safety: Regulatory Reform for Hazardous Liquid Pipelines”
    PHMSA
    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...
  • 666KB, PDF
    04/06/2020
    Joint Association Comments on PHMSA’s Automated Valve Proposed Rulemaking
    PHMSA
    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 ...
  • 1MB, PDF
    02/03/2020
    Natural Gas Coalition Letter to Members of the Subcommittee on Energy
    Subcommittee on Energy, Committee on Energy & Commerce
    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, ...
  • 276KB, PDF
    10/31/2019
    Joint Association Petition for Reconsideration Regarding § 192.5(d) and § 192.624(a)(1) of the Gas Transmission Rule
    PHMSA
    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”) ...
  • 1MB, PDF
    08/23/2019
    Joint Trade Comments to DOE Regarding Resilience Standards
    DOE
    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 ...
  • 122KB, PDF
    07/17/2019
    Joint Association Letter in Support of Pipeline Safety Advisory Committees
    The Honorable Elaine L. Chao
    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 ...
  • 324KB, PDF
    05/08/2019
    RESPONSE TO NOTICE OF REVIEW OF GUIDANCE
    DOT
    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 ...
  • 400KB, PDF
    04/29/2019
    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 ...
  • 453KB, PDF
    04/10/2019
    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 ...
  • 355KB, PDF
    04/02/2019
    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 ...
  • 129KB, PDF
    03/28/2019
    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 ...
  • 166KB, PDF
    02/07/2019
    Multi-Group Letter to DOT Secretary Chao in Support of PHMSA Gas Transmission Rule
    The Honorable Elaine L. Chao
    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 ...
  • 180KB, PDF
    12/28/2018
    FERC
    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 ...
  • 256KB, PDF
    12/17/2018
    Guidance on the Extension of the 7-year Integrity Management Reassessment Interval by 6 Months
    PHMSA
    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 ...
  • 264KB, PDF
    10/30/2018
    EPA
    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 ...
  • 135KB, PDF
    10/01/2018
    PHMSA Administrator Howard "Skip" Elliott
    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 ...
  • 310KB, PDF
    10/01/2018
    FERC
    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”) ...