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
  • Construction 2
  • Economics 10
  • Environment 22
  • Executive Branch 2
  • Regulatory 42
  • Safety 16
  • Security 1
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Filing
  • Filing 318
  • Letter 49
  • Testimony 23
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  • IASB 3
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  • NTSB 1
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  • OSHA 5
  • PHMSA 47
  • USDC 1
  • USFWS 6
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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 ...
  • 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 ...
  • 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 ...
  • 507KB, PDF
    08/20/2018
    Mr. Edward Boling, Council on Environmental Quality
    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 ...
  • 2MB, PDF
    06/06/2018
    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 ...
  • 275KB, PDF
    06/05/2018
    FERC
    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 ...
  • 385KB, PDF
    05/21/2018
    FERC
    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 ...