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 0
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  • Economics 10
  • Environment 25
  • Executive Branch 2
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  • Safety 16
  • Security 1
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Filing
  • Filing 325
  • Letter 49
  • Testimony 23
Agency
  • Administration 0
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  • IASB 3
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  • NTSB 1
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  • PHMSA 48
  • USDC 1
  • USFWS 6
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  • 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 ...
  • 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 ...
  • 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 ...
  • 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 ...
  • 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 ...
  • 865KB, PDF
    12/17/2018
    INGAA Comments on Subpart OOOOa
    EPA
    INGAA
    Dear Docket Clerk:

    The Interstate Natural Gas Association of America (INGAA), a trade association of the interstate natural gas pipeline industry, respectfully submits these comments in response to the Environmental Protection Agency’s (EPA) proposed rule, “Oil and Natural Gas ...
  • 1MB, PDF
    12/14/2018
    INGAA Comments on Subpart OOOOa
    Sandra Snyder, INGAA
    Innovative Environmental Solutions, Inc.
    In June 2018, INGAA provided several documents to EPA regarding fugitive emissions data to substantiate its position that fugitive emissions monitoring at compressor stations should be less frequent than quarterly. EPA’s review of that material is provided in an EPA memo titled “EPA ...
  • 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 ...
  • 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”) ...
  • 936KB, PDF
    09/24/2018
    U.S. Fish and Wildlife Service, National Marine Fisheries Service
    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 ...