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 27
  • Executive Branch 2
  • Regulatory 42
  • Safety 19
  • Security 1
Type
  • Filing 326
  • Letter 49
  • Testimony 24
Agency
  • Administration 0
  • BLM 1
  • Bureau of Indian Affairs 3
  • CARB 1
  • CEQ 4
  • CFTC 2
  • Congress 2
  • CorpsEngineers 7
  • DHS 1
  • DOE 2
  • DOGGR 1
  • DOI 4
  • DOT 7
  • EPA 72
  • FAA 0
  • FEMA 1
  • FERC 144
  • IASB 3
  • NOAA 2
  • NTSB 1
  • NYSDEC 1
  • OSHA 5
  • PHMSA 48
  • USDC 1
  • USFWS 6
Date
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  • 326KB, PDF
    03/15/2021
    Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990–2019
    EPA
    INGAA
    Dear Docket Clerk:

    The Interstate Natural Gas Association of America (“INGAA”), a trade association representing the interstate natural gas pipeline industry, respectfully submits these comments in response to the Environmental Protection Agency’s (“EPA”) notice of ...
  • 389KB, PDF
    03/10/2021
    Sandra Snyder Testifies at Senate EPW Hearing
    Chairman Carper, Ranking Member Capito, and Members of the Committee: Good morning. My name is Sandra Snyder, and I am the Vice President of Environment at the Interstate Natural Gas Association of America (INGAA). Thank you for holding this hearing and the opportunity to testify today...
  • 858KB, PDF
    12/15/2020
    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 ...
  • 260KB, *
    12/14/2020
    PHMSA Class Change NPRM Comments
    PHMSA
    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 ...
  • 121KB, PDF
    11/19/2020
    Coalition Letter in Support of FERC Confirmations
    The Honorable Mitch McConnell & The Honorable Chuck Schumer
    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 ...
  • 497KB, PDF
    11/16/2020
    INGAA Comments on Proposal to Reissue and Modify Nationwide Permits, 85 Fed. Reg. 57,298
    U.S. Army Corps of Engineers
    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 ...
  • 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 ...
  • 825KB, PDF
    03/10/2020
    INGAA Comments on CEQ NEPA Regulations
    Mr. Edward Boling, Council on Environmental Quality
    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 ...
  • 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, ...
  • 143KB, PDF
    11/25/2019
    Comments on Methane Policy
    Ms. Amy Hambrick
    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 ...
  • 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 ...