Username
Password
Forgot your password?

comments | motions | testimony

Latest updates:

APGA Files Comments with the UNITED STATES DEPARTMENT OF TRANSPORTATION: Pipeline and Hazardous Materials Safety Administration PHMSA You can read the comments here.

EIA Jan 2012 Report - Effect of Increased Natural Gas Exports on Domestic Energy Markets as requested by the Office of Fossil Energy. Please also read TESTIMONY OF JIM COLLINS DIRECTOR OF UNDERGROUND UTILITIES FOR THE CITY OF HAMILTON, OHIO ON BEHALF OF THE AMERICAN PUBLIC GAS ASSOCIATION BEFORE THE SENATE ENERGY AND NATURAL RESOURCES COMMITTEE Click here for testimony.

Petition to Review for APGA vs DOE

Petition to review to the Appeals Courts for DC Circuit for American Public Gas Association vs Department about the direct final rule and notice of an effective date in the Energy Energy Conservation Program: Energy Conservation Standards for Residential Furnaces and Residential Central Air Conditioners and Heat Pumps. Read it here.

November 21, 2011 - DEPARTMENT OF TRANSPORTATION PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION 49 CFR Part 192 [Docket No. PHMSA-2011-0009] RIN 2137-AE71 Pipeline Safety: Expanding the Use of Excess Flow Valves in Gas Distribution Systems to Applications Other Than Single-Family Residences click here for Advance Notice of Proposed Rulemaking (ANPRM)..

APGA Files Comments at Department of Energy

September 21, APGA filed comments with the Department of Energy (DOE) in response to their Request for Information (RFI) on developing a voluntary National Asset Rating Program for Commercial Buildings (AR Program). 

MOTION FOR LEAVE TO INTERVENE AND PROTEST OF THE AMERICAN PUBLIC GAS ASSOCIATION

Pursuant to Sections 590.303 and 590.304 ofthe Administrative Procedures with Respect to the Import and Export ofNatural Gas,l the American Public Gas Association ("APGA") files this motion to intervene and protest in the above captioned proceeding. Read it here.

July 14, 2011 - TESTIMONY OF THE AMERICAN PUBLIC GAS ASSOCIATION BEFORE THE HOUSE ENERGY AND COMMERCE SUBCOMMITTEE ON ENERGY AND POWER. Click here to view the testimony

.APGA Files Comments Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants

July 7, 2011, APGA filed comments on the Commodity Futures Trading Commission’s (“Commission”) “Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants,” 76 Fed. Reg. 23732; RIN 3038—AC97 (April, 28, 2011) (“Margin Notice”) and “Capital Requirements of Swap Dealers and Major Swap Participants,” 76 Fed. Reg. 27802; RIN 3038—AD54 (May 12, 2011) (“Capital Notice”). You can read the comments here.

APGA Files Comments with HUD on Full-Fuel-Cycle

June 30, APGA filed comments on a HUD information collection proposal that urges HUD to require applicants for Energy Innovation Funds (EIF) under the Multifamily Pilot Program to affirm , in their application, the use of the least costly and most efficient and environmentally friendly energy equipment and appliances in HUD subsidized multifamily housing. APGA states this will require the applicant to use full-fuel-cycle analysis to calculate the efficiency, emission characteristics and cost of multi-fuel equipment and appliance options. A copy of APGA’s comments can be viewed on the APGA website here.

June 23, 2011 - APGA Submits Comments on Margin and Capital Requirements for Covered Swap Entities Read them here.

 

June 16, 2011 - TESTIMONY OF THE AMERICAN PUBLIC GAS ASSOCIATION BEFORE THE HOUSE ENERGY AND COMMERCE SUBCOMMITTEE ON ENERGY AND POWER HEARING ON PIPELINE SAFETY AND OVERSIGHT. You view the testimony here.

APGA Submits Comments to FERC on NOPR for Bidding by Affiliates in Open Seasons for Pipeline Capacity

May 31, 2011 - APGA submitted comments to the Federal Energy Regulatory Commission in response to a Notice of Proposed Rulemaking that addresses Bidding by Affiliates in Open Seasons for Pipeline Capacity. In its comments, APGA expresses support for the Commission’s proposal to prohibit multiple affiliates of the same entity from bidding in an open season for pipeline capacity, unless each affiliate has its own business reason for bidding. APGA also supports the Commission’s proposal to prohibit affiliates from consolidating pipeline capacity obtained in a pro rata allocation. APGA also recommends that the Commission regulations be revised to require that, if affiliates of the same entity do participate in open seasons for pipeline capacity, each be required to identify itself as such in its bid and that any award of open season capacity likewise note that fact. A copy of APGA’s comments can be viewed on the APGA website here.

American Infrastructure Investment Fund Act of 2011

On May 11, Senators Rockefeller (D-WV), Chairman of the Senate Commerce Committee, and Lautenberg (D-NJ), Chairman of the Commerce Subcommittee on Surface Transportation, introduced legislation entitled the American Infrastructure Investment Fund Act of 2011. Click here to read a copy of the bill and a section-by-section summary.

APGA Files Comments with DEPARTMENT OF ENERGY OFFICE OF FOSSIL ENERGY

On March 28, 2011 filed comments pursuant to Sections 590.303 and 590.304 of the Administrative Procedures with Respect to the Import and Export of Natural Gas, 1 the American Public Gas Association (“APGA”) files this motion to intervene and protest in the above captioned proceeding  FE Docket No. 10-161-LNG.

APGA Files Comments with FERC

On February 22, 2011, APGA submits its response to the Commission’s request for comments regarding whether the Commission should modify the semi-annual storage reports required of interstate and intrastate natural gas companies pursuant to 18 CFR §§ 284.13(e) and 284.126(c) of the Commission’s regulations. 

APGA Files Comments with SEC

On February 22, 2011, APGA filed comments with the Securities and Exchange Commission’s (“SEC’s” or “Commission’s”) on Registration of Municipal Advisors; Release No. 34-63576; File No. S7-45-10. 

APGA Files Comments with CFTC on Three Rules

On February 22, 2011, APGA filed comments with the CFTC on End-User Exception to Mandatory Clearing of Swaps, Definition of Eligible Contract Participant, and Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties.

APGA Files Comments on Public Version 2.0 of the International Green Construction Code

January 3, APGA collaborated with GTI, Laclede Gas and the National Propane Gas Association to file joint comments on Public Version 2.0 of the International Code Council new International Green Construction Code (IgCC).  This same collaboration was undertaken on comments filed on IgCC Public Version 1.0 in May 2010 and in addressing a public hearing in August 2010.  The January 3 comments can be seen here.  The supporting graphics for the comments can be seen here.  

APGA Comments on Draft Energy Reform Legislation for 112th Congress

CGC asked that comments added to the  Discussion Draft are presented in red-line format - view the document here.  APGA’s comments specifically focused on needed revisions to promote natural gas vehicles and fueling stations and to give full credit to the efficiency and emission advantages of natural gas.

APGA Files Motion to Intervene in FERC case against Ozark Gas Transmission LLC and Kinder Morgan Interstate Gas Transmission LLC

APGA Files Motion to Intervene in Pursuant to Rule 214 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure and the November 18, 2010 Order of the Commission in this proceeding, the American Public Gas Association (“APGA”) hereby submits the instant motion to intervene in the above-captioned proceeding against Ozark Gas Transmission, LLC and Kinder Morgan Interstate Gas Transmission LLC.

October 7, 2010 - Read the Full CFTC Interim Final Rule on Reporting as well as a Q & A about it and an overview.

September 28, 2010 - TESTIMONY OF THE AMERICAN PUBLIC GAS ASSOCIATION SUBMITTED TO THE SENATE COMMERCE, SCIENCE AND TRANSPORTATION SUBCOMMITTEE ON SURFACE TRANSPORTATION AND MERCHANT MARINE INFRASTRUCTURE, SAFETY, AND SECURITY HEARING ON PIPELINE SAFETY: ASSESSING THE SAN BRUNO, CALIFORNIA EXPLOSION AND OTHER RECENT ACCIDENTS. You view the testimony here.  If you want to read the Feinstein-Boxer Pipeline safety bill click here.

September 23, 2010 - TESTIMONY OF THE AMERICAN PUBLIC GAS ASSOCIATION BEFORE THE HOUSE ENERGY AND COMMERCE SUBCOMMITTEE ON ENERGY AND ENVIRONMENT HEARING ON PIPELINE SAFETY AND OVERSIGHT. You view the testimony here.

APGA Files Petition with CFTC ON BEHALF OF ITS MEMBERS TO REMAIN SUBJECT TO THE EXISTING PROVISIONS OF SECTION 2(h) OF THE COMMODITY EXCHANGE ACT

The American Public Gas Association (APGA) respectfully submits this petition to the U.S. Commodity Futures Trading Commission (the "Commission") on behalfofits members (a listing of members is attached) and requests that the Commission, pursuant to Section 723(c) of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (the "Dodd-Frank Act") allow its members to continue to rely on the exemptions set forth in § 2(h) of the Commodity Exchange Act (the "CEA") for a period of one year after the Effective Date! of the Dodd-Frank Act, or for such other period as the Commission deems appropriate. Read here.

July 21, 2010 - Sam Davis, General Manager of Lake Apopka, FL testified on behalf of APGA in the House Transportation and Infrastructure Subcommittee on Railroads, Pipelines and Hazardous Materials. The focus of the hearing is Pipeline Safety Public Awareness and Education. . You view the testimony here.

July 9, APGA filed comments with DOE on its National Energy Rating Program for Homes. APGA collaborated with GTI, Laclede Gas and the National Propane Gas Association in preparing comments but each organization filed separately . Click here to read the comments.

July 15 2010 - Dodd-Frank Wall Street Reform and Consumer Protection Act passed Congress. The derivatives title can be found here.

June 24, 2010- Testimony of The American Public Gas Association Before The Senate Commerce, Science And Transportation Subcommittee On Surface Transportation And Merchant Marine Infrastructure, Safety, And Security Hearing On Ensuring The Safety Of Our Nation’s Pipelines here.

June 23, 2010 - House summary and text of Section Title VII of Wall Street Transparency and Accountability Act of 2010.

APGA files comments on Natural Gas Pipeline Company of America LLC - Docket No. RP10-147-000

June 21, 2010 - Pursuant to Rule 602 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure,1 the American Public Gas Association (“APGA”) files these comments regarding the Stipulation and Agreement (“S&A”) filed with the Commission by Natural Gas Pipeline Company of America LLC (“Natural”) in the subject proceeding on May 21, 2010. APGA takes no position regarding the S&A2 but rather comments for the purpose of putting this proceeding in proper perspective.Click here to see the comments here.

APGA files comments on Great Lakes Gas Transmission Limited Partnership - Docket No. RP10-149-000

June 2, 2010 - Pursuant to Rule 602 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure,1 the American Public Gas Association (“APGA”) files these comments regarding the Stipulation and Agreement (“S&A”) filed with the Commission by Great Lakes Gas Transmission Limited Partnership (“Great Lakes”) in the subject proceeding on May 21, 2010. APGA takes no position regarding the S&A2 but rather comments for the purpose of putting this proceeding in proper perspective.Click here to see the comments here.

APGA files comments on COMNET proposed guidelines & procedures

On May 14, 2010 Bob Beauregard of APGA filed comments on the COMNET proposed guidelines and procedures.  Click here to see the comments here.

May 20, 2010 - TESTIMONY OF THE AMERICAN PUBLIC GAS ASSOCIATION BEFORE THE HOUSE TRANSPORTATION AND INFRASTRUCTURE SUBCOMMITTEE ON RAILROADS, PIPELINES AND HAZARDOUS MATERIALS HEARING ON IMPLEMENTATION OF THE PIPELINE INSPECTION, PROTECTION, ENFORCEMENT AND SAFETY ACT OF 2006 AND REAUTHORIZATION OF THE PIPELINE SAFETY PROGRAM is found here.

Response to Motion Filed by Northern Customer Group to terminate section 5 proceedings

Pursuant to Rule 213 of the Federal Energy Regulatory Commission’s (“Commission”) Rules of Practice and Procedure,1 the American Public Gas Association (“APGA”) files this response to the motion of the Northern Customer Group (“Customer Group”) to terminate the subject section 5 proceeding. APGA takes no position regarding the requested relief but rather responds for the purpose of highlighting certain facts and issues raised by the Customer Group Motion.  Read here.

 

APGA Files Comments with CFTC on position limits

Click here to view the April 27, 2010 APGA comments filed with CFTC.

FERC's Order No. 717C - Rehearing and Clarification on 717 - April 16 2010

APGA filed for clarification that a pipeline providing privileged non-public transmission information to a marketing employee would constitute a violation of NGA section 4.  FERC's response:

Although we deny APGA’s request for rehearing and clarification, we note that the exclusion must be read in the context of the whole of the Standards of Conduct. For example, section 358.2(a) of the Commission’s regulations specifies that “A transmission provider must treat all transmission customers, affiliated and non-affiliated, on a non-discriminatory basis and must not make or grant any undue preference or advantage to any person or subject any person to any undue prejudice or disadvantage with respect to any transportation of natural gas….” , while section 358.2(d) further provides that “A transmission provider must provide equal access to non-public transmission function information to all its transmission customers, affiliated and non-affiliated, except in the case of confidential customer information or Critical Energy Infrastructure Information.” Read full order here.

JOINDER IN PROTESTS OF THEAMERICAN PUBLIC GAS ASSOCIATION

Pursuant to Rule 211 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“Commission”), the American Public Gas Association (“APGA”), an intervenor in each of the above-designated proceedings, files this Joinder in Protests regarding the “cost and revenue” studies filed respectively by Natural Gas Pipeline Company of America, LLC (“Natural”), Northern Natural Gas Company (“Northern”), and Great Lakes Gas Transmission Company (“Great Lakes”), collectively the “Respondent Pipelines.” Read here.

Environmental Protection Agency (EPA) rule compliance 

The Environmental Protection Agency (EPA) issued a final rule requiring all natural gas utilities to report to EPA their yearly emissions from gas delivered to residential, commercial, industrial and electric generation users. To view summary, compliance checklist, and template APGA has designed to help you comply please go to www.apga.org/epa.

APGA Files Motion to Intervene in FERC Section 5 Proceedings

Read APGA's motion against Great Lakes Gas Transmission LLC here, against Natural Gas Pipeline Company of America LLC here, and Northern Natural Gas Company here.

APGA and Others File Joint Intervention in INGAA vs. FERC

On November 16, APGA, the American Gas Association, the Natural Gas Supply Association, the American Forest and Paper Association and several other associations jointly filed an interventor brief in the Interstate Natural Gas Association of America (INGAA) v. FERC. The case is currently before the United States Court of Appeals for the District of Columbia Circuit. The joint brief filed by APGA and the other associations opposes an appeal by INGAA regarding FERC’s decision to not deregulate short-term pipeline transportation at the same time it deregulated short-term capacity releases. The joint intervenor brief points out, among other things, that the quid pro quo for deregulating pipeline sales – namely, a showing of no market power – was not made by the pipelines and that one of the reasons given by the Commission for deregulating capacity sales was the continued regulation of pipeline sales so that shippers always have access to cost-based recourse rates. FERC also filed a brief opposing the INGAA position. 

APGA Submits Testimony on the Role of Natural Gas in Mitigating Climate Change

The American Public Gas Association submitted testimonies to the Senate Environment and Public Works and the Senate Energy and Natural Resources Committee on the role of natural gas in mitigating climate change.  Click on the links to view the testimonies.

Click here to view the October 26 2009 APGA comments filed with FERC.

Testimony of CFTC Chairman Gensler on OTC Derivatives Before the House Committee on Financial Services

Click here to view the testimony of CFTC Chairman Gensler on OTC Derivatives Market Act of 2009 Before the House Committee on Financial Services. Click here to read the OTC Derivatives Market Act 2009.

OTC Derivates Discussion Draft by Rep. Frank was Released Oct 6, 2009

Click here to view the discussion draft from Rep. Frank was released today. The PDF of the draft is attached.

Boxer-Kerry Climate Change Bill

Click here to read the Senate introduced Boxer-Kerry climate change draft and here for the summary of the bill..

APGA Comments on Greenhouse Gas Emission Reporting Proposed Rule
On June 9 APGA filed comments with the Environmental Protection Agency (EPA) on EPA’s proposed Greenhouse Gas Emission Reporting Rule. APGA’s comments strongly opposed EPA’s requirement that all meters used to measure natural gas deliveries be recalibrated in calendar year 2010. Our comments pointed out that this would affect over 68 million customer meters, as well as the many custody transfer meters from which public gas systems receive gas from their pipeline suppliers.

Comments of the AMERICAN PUBLIC GAS ASSOCIATION on Section 5 reform

APGA plans to submit the attached testimony regarding NGA Section 5 reform and cease and desist authority for the Energy Subcommittee hearing tomorrow.  Our comments on cease & desist authority begin on Page 10.  We also plan to submit the full Natural Gas Supply Association study on pipeline overcharges. 

Comments of the AMERICAN PUBLIC GAS ASSOCIATION in Response to the Notice of Inquiry

On February 13, 2009  - Pursuant to the Notice of Inquiry (“NOI”) issued by the Federal Energy Regulatory Commission (“Commission” or "FERC”) in the above-captioned proceeding on November 20, 2008, the American Public Gas Association (“APGA”) hereby submits its response to the Commission’s request for comments regarding contract reporting requirements for those natural gas pipelines that fall under the Commission’s jurisdiction pursuant to section 311 of the Natural Gas Policy Act of 19781 or section 1(c) of the Natural Gas Act. Read the text here.

New CFTC Bill Submitted on H.R. 977

On February 11, 2009 the House Agriculture Committee on Derivatives Legislation Chair introduced the Bill on H.R. 977. Read the text here.

Submitted Testimony of the American Public Gas Association Before the House Agriculture Committee on Derivatives Legislation

On February 3, 2009 the American Public Gas Association submitted testimony before the House Agriculture Committee on Derivatives Legislation.

Solicitation of Comments on the Process and Technologies Used for Disseminating the Weekly Petroleum Status Report and the Weekly Natural Gas Storage Report

November 17, 2008, “Pursuant to the request for comments issued by the Energy Information Administration (“EIA”) on October 15, 2008, the American Public Gas Association (“APGA”) hereby submits comments on the process and technologies used for disseminating the Weekly Petroleum Status Report (“WPSR”) and the Weekly Natural Gas Storage Report (“WNGSR”).”

Summary of the Proposed Distribution Integrity Management Programs (DIMP) Rule

On June 25 the Pipeline And Hazardous Materials Safety Administration (PHMSA) proposed new regulations requiring distribution operators to develop and follow a written Distribution Integrity Management Programs (DIMP) program. PHMSA is seeking public comments up until September 23 after which it will consider the comments an issue a Final Rule. APGA is already drafting comments on the rule.

APGA Vice-Chair Mike Comstock Submits Testimony Before House Agriculture Committee

July 09, 2008, 2008-09 APGA Chair Mike Comstock Submits Testimony Before House Agriculture Committee about the rising prices of natural gas. You can click here for his submitted testimony and here for his oral testimony.

APGA Files Comments on FERC's NOPR on Pipeline Posting Requirements

On March 13, 2008, the APGA filed comments on the Federal Energy Regulatory Commission's (FERC) Notice of Proposed Rulemaking on Pipeline Posting Requirements. 

APGA Files Motion on FERC Enforcement Action Against Amaranth

On March 12, 2008, APGA, the American Public Power Association (APPA) and the National Rural Electric Cooperative Association (NRECA) filed a motion with U.S. Court of Appeals for the District of Columbia Circuit to file an amicus brief in support of FERC's authority to file an enforcement action against Amaranth.

APGA and AGA Submit Joint Testimony at House Pipeline Safety Hearing

On March 13, 2008, the APGA filed comments on the Federal Energy Regulatory Commission's (FERC) Notice of Proposed Rulemaking on Pipeline Posting Requirements. Under the FERC proposal, both interstate pipelines and certain major non-interstate pipelines would be required to post capacity, daily scheduled flow information, and daily actual flow information. In its comments, APGA commends FERC for its efforts to increase market transparency through this proposed rule.

APGA Files Comments in Rulemaking Revising Capacity Release Regulations

On January 25, 2008, APGA filed comments with the Federal Energy Regulatory Commission (FERC) in its proposed revision to its regulations governing the release of firm capacity on interstate natural gas pipelines by permanently removing the rate cap on capacity release transactions of one year or less.