Regulatory Submissions

All 2013 APGA Comments and Motions 

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FE Docket No 12-101-LNG 1_7.pdf   3.77 MB   1 version
Uploaded - 07-12-2015
January 4, 2013 - APGA filed a motion to intervene and protest at the Dept of Energy's Office of Fossil Energy in response to an application filed by Gulf LNG Liquefaction Company LLC to export approximately 1.5 billion cubic feet per day of LNG from an existing Gulf LNG terminal in Mississippi to any country with which the US does not have a Free Trade Agreement with
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APGA AD12-12 Comments 010713.pdf   31 KB   1 version
Uploaded - 07-12-2015
January 7, 2013 - APGA submitted response to Notice of Request by Federal Energy Regulatory Commission on the Coordination between Natural Gas and Electricity Markets.
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1_23_13 APGA Comments on the 2012 LNG Export Study.pdf   203 KB   1 version
Uploaded - 07-12-2015
January 24, 2013 - Initial comments of the the American Public Gas Association in response to the 2012 LNG Export Study
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FE Docket No 12-156-LNG protest.pdf   4.47 MB   1 version
Uploaded - 07-12-2015
February 4, 2013 - APGA filed three Motions for Leave to Intervene and Protest with Respect to the Import and Export of Natural Gas with Golden Pass Products LLC
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FE Docket No 12-123-LNG protest.pdf   5.35 MB   1 version
Uploaded - 07-12-2015
February 4, 2013 - APGA filed three Motions for Leave to Intervene and Protest with Respect to the Import and Export of Natural Gas with CE FLNG LLC
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FE Docket No 12-146-LNG protest.pdf   3.69 MB   1 version
Uploaded - 07-12-2015
February 4, 2013 - APGA filed three Motions for Leave to Intervene and Protest with Respect to the Import and Export of Natural Gas with Excelerate Liquefaction.
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NAESB Waiver protest 021213.pdf   25 KB   1 version
Uploaded - 07-12-2015
February 12, 2013 - APGA filed a Protest pursuant to Rule 211 of the Rules and Procedure of FERC against thirteen FERC-jurisdictional natural gas transportation service providers owned by Spectra Energy Corp. who filed January 31 2013 to amend their respective tariffs to include new waiver language explicitly authorizing the pipelines to reproduce sections of the latest version of the North American Energy Standards Board (“NAESB”) Wholesale Gas Quadrant (“WGQ”) Business Practices and Electronic Communications Standards (“NAESB WGQ Version 2.0”)
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Comments to DOE re water heater testing procedures RFI 2 ....pdf   27 KB   1 version
Uploaded - 07-12-2015
February 11, 2013 - Comments from the American Public Gas Association on Energy Conservation Program: Test Procedures for Residential Water Heaters and Commercial Water Heaters— 10 CFR Part 430
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APGA RM13-1 Comments 021213.pdf   20 KB   2 versions
Uploaded - 07-12-2015
February 12, 2013 - Comments of the American Public Gas Association in response to the Notice of Inquiry issued by FERC on Enhanced Natural Gas Market Transparency
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Test Procedures for Residential Furnaces.pdf   22 KB   1 version
Uploaded - 07-12-2015
February 19, 2013 - Comments of the American Public Gas Association submitted comments in response to the Request for Information (RFI) issued by the U.S. Department of Energy (DOE) on January 4, 2013, to initiate the rulemaking and data collection process to consider amendments to DOE’s test procedure for residential furnaces and boilers (Energy Conservation Program: Test Procedures for Residential Furnaces [EERE-2011-BT-TP-0024 and/or RIN 1904-AC79])
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APGA Comments to GSA Green Buildings RFI (Notice-MG-2012-04).pdf   217 KB   1 version
Uploaded - 07-12-2015
April 8, 2013 - APGA filed comments in response to Request for Information issued by U.S. General Services Administration (GSA) in the Federal Register on February 5, 2013 seeking public input on the green building certification system(s) for use by the Federal governme
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APGA Comments on Distribution.pdf   441 KB   1 version
Uploaded - 07-12-2015
April 15, 2013 - APGA filed comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) suggesting changes to the instructions of the Distribution Annual Report (Form 7100-1.1) to make leap repair cause description consistent with definiitions from the Distrtibution Incident Report (Form 7100-1.1)
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APGA Comments to Furnace Testing Procedures.pdf   235 KB   1 version
Uploaded - 07-12-2015
April 22, 2013 - APGA filed comments in response the to notice of proposed rulemaking regarding test procedures for two - stage and modulating condensing furnaces and boilers issued by the U.S. Department of Energy (DOE), Office of Energy Efficiency and Renewable Energy (EERE), in the Federal on February 4 , 2013
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Trunkline 13-04-LNG protest.pdf   2.05 MB   1 version
Uploaded - 07-12-2015
May 20, 2013 - APGA filed a Motion for Leave to Intervene and Protest with Respect to the Export of domestic natural gas as liquefied natural gas (LNG) with Trunkline LNG Export
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APGA Comments to Elec Resistance 55 gallon WHs.pdf   216 KB   1 version
Uploaded - 07-12-2015
April 29, 2013 - APGA filed comments in response to Notice of Proposed Rulemaking Waiver of Federal Minimum Efficiency Standard for Electric Storage Water Heaters with Storage Volumes over 55 Gallons issued by the U.S. Department of Energy (DOE), Office of Energy Efficiency and Renewable Energy (EERE), in the Federal Register on February 26 , 2013.
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apga13_26_lng08_05_13.pdf   946 KB   1 version
Uploaded - 07-12-2015
August 5, 2013 - APGA filed a Motion for Leave to Intervene and Protest with Respect to the Import and Export of Natural Gas with Freeport-McMoRan Energy LLC.
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APGA comments on class location ANPRM 8-31-13.pdf   107 KB   1 version
Uploaded - 07-12-2015
August 27, 2013 - APGA filed comments in response to a Notice of Proposed Rulemaking by FERC in the July 18 2013 Communication of Operational Information Between Natural Gas Pipelines and Electric Transmission Operators proceeding (Docket No. RM13-17-000). As a general matter, APGA supports the Commission’s recognition of the significant gas-electric coordination issues that need to be addressed; however, in this instance, APGA believes that the proposed rule in the NOPR opens the door to the release of commercially-sensitive non-public information without adequate support for such action and without adequate guidelines for such release.
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APGA Comments to DOE Methodology RFI 9_5_13.pdf   215 KB   1 version
Uploaded - 07-12-2015
September 5, 2013 - The American Public Gas Association (APGA) is pleased to submit comments to the U.S. Department of Energy (DOE), Office of Energy Efficiency and Renewable Energy (EERE) in response to DOE’s request for information (RFI) on the methodology developed by DOE to assist in assessing compliance with building energy codes at the local, state, and national levels in the Federal Register on August 6, 2013.
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APGA_Comments_to_SCC.pdf   208 KB   1 version
Uploaded - 07-12-2015
September 19, 2013 - APGA submitted comments in response to the request for public comment on the Petition for Reconsideration of the Department of Energy’s Final Rule: Energy Conservation Standards for Standby Mode and Off Mode for Microwave Ovens issued by the U.S. Department of Energy (DOE) in the Federal Register on August 16, 2013.
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Draft BPI Standards Comments - Final.pdf   87 KB   1 version
Uploaded - 07-12-2015
November 18, 2013 - APGA submitted comments in response to the Building Performance Institute (BPI)'s proposed BPI-1200-S-201X: Standard Practice for Basic Analysis of Buildings. The Proposed Standard discourages the use of natural gas appliances by developers and builders, by imposing undue technical requirements and unnecessary repeated tests on correctly installed natural gas appliances, as well as recommending the removal of atmospherically vented appliances without justification. Natural gas appliances are more much more efficient than electric appliances and cost the consumer far less to operate. APGA believes the technical requirements, installation procedures, and recommended tests already imposed by the American National Standards Institute (ANSI), the National Fuel Gas Code (NFGC), and the International Fuel Gas Code (IFGC) are sufficient to monitor the safety of natural gas appliances.
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APGA Comments on Revisions to Incident12-20-13.pdf   248 KB   1 version
Uploaded - 07-12-2015
December 20, 2013 - APGA submitted comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) opposing PHMSA’s proposal to require distribution systems that have lines classified as transmission to report how much gas flows through those lines as part of the transmission and gathering annual reports

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