Federal Filings

comments | motions | testimony

Latest updates:

  • October 7, 2014 - APGA requested that the North Carolina Utilities Commission (NCUC) to allow its Petition to Intervene in Docket No. E-100, Sub 134 in the matter of filing requirements for New Electric Generators. Read the motion here.
  • October 6, 2014 - APGA sent a letter to the Office of Energy Policy and Systems Analysis in response to the Department of Energy's (DOE) request for written comments for the Quadrennial Energy Review (QER) Task Force. Read the letter and comments here.
  • On October 1, APGA filed written comments with Federal Regulatory Agency Commission (FERC) in response to a meeting on September 18 with Commissioner Philip D. Moeller about the rolodex trading of natural gas (Docket No. AD14-19-000) in regards to the harmonization of gas and electric industries. APGA cautions that enhancements brought up during that meeting will not adequately address the reliability problem relating to gas-fired generation such as the failure of RTO/ISOs to promulgate market rules that incentivize generators relying on natural gas to make the necessary investments either in firm pipeline capacity or other infrastructure improvements (such as LNG backup or additional pipeline connections or dual fuel capability). Read the comments here.
  • September 20, 2014 - APGA filed a motion to Intervene and Protest in Gasfin Development USA, LLC's application in FE Docket No. 13-161-LNG that would seek long-term authorization to export approximately 74 billion cubic feet per year (“Bcf/y”) of domestic natural gas as liquefied natural gas as liquefied natural gas ("LNG") by by vessel to any country which has, or in the future develops, the capacity to import LNG and with which the United States does not have a free trade agreement requiring national treatment for trade in natural gas or LNG and with which trade is not prohibited by United States law or policy (“non-FTA Nations”). Read the motion here.
  • September 15, 2104 - APGA filed a motion to Intervene and Protest in Waller LNG Services LLC's application in FE Docket No. 13-153-LNG that would seek long-term authorization to export approximately 70 billion cubic feet per year (“Bcf/y”) of domestic natural gas as liquefied natural gas as liquefied natural gas ("LNG") by by vessel to any country which has, or in the future develops, the capacity to import LNG and with which the United States does not have a free trade agreement requiring national treatment for trade in natural gas or LNG and with which trade is not prohibited by United States law or policy (“non-FTA Nations”).3 Waller Point’s Application seeks authorization to export LNG from a natural gas liquefaction and LNG export terminal to be located at the entrance point of the Calcasieu Ship Channel in Cameron Parish, Louisiana. Read the motion here.
  • September 2, 214 - APGA filed a motion to Intervene and Protest in Emera CNG, LLC ("Emera")'s application in FE Docket No. 13-157-CNG that would seek long-term authorization to export approximately  billion cubic feet per year (“Bcf/y”) of domestic natural gas as liquefied natural gas as compressed natural gas ("CNG") by ocean-going carrier to “(1) any country with which the United States currently has, or in the future may enter into, a free trade agreement (“FTA”) requiring national treatment for trade in natural gas and (2) any country with which the United States does not have a FTA requiring national treatment for trade in natural gas, which currently has or in the future develops the capacity to import CNG and with which trade is not prohibited by United States law or policy." Read the motion here.
  • On August 18, APGA filed written comments with the Federal Trade Commission (FTC) on the 2014 Supplemental Notice of Proposed Rulemaking on Energy Labeling Rule Regulatory Review focusing on the energy labeling requirements for furnaces. Read the comments here.
  • July 28, 2014 - Opening statement of Joe Holmes of Colorado Springs Utilities, Colo. for the DOE Quadrennial Energy Review Meeting. Read the testimony here.
  • July 21, 2014 - APGA filed written comments expressing support about the Notice of Proposed Procedure (NOPP) on July 4 79 Fed. Reg. 32,261 regarding changing its process for reviewing LNG export applications. Specifically, DOE proposed to make final public interest determinations on an LNG export application only after completion of the review required by environmental laws and regulations that are included in the National Environmental Policy Act (NEPA). Read the comments here.
  • July 21, 2014 - Opening statement of Jim Sullivan, Chairman of the Norwich, Conn. Board for Norwich Public Utilities Commissioners, at the DOE Quadrennial Energy Review Meeting. Read the testimony here.
  • June 27, 2014 APGA filed a motion to Intervene and Protest in Venture Global LNG, LLC (“Venture Global”)'s application in FE Docket No. 13-69-LNG that would seek long-term authorization to export approximately 243.6 billion cubic feet per year (“Bcf/y”) of domestic natural gas as liquefied natural gas (“LNG”) by vessel to any country which has, or in the future develops, the capacity to import LNG via oceangoing carrier and with which the United States either: (1) has a free trade Agreement requiring national treatment for trade in natural gas; or (2) with which the United States does not have a free trade agreement but with which trade is not prohibited by U.S. law or policy (“non-FTA Nations”). Read the motion here.
  • On June 19, the Federal Energy Regulatory Commission (FERC) granted authorization under Section 3 of the Natural Gas Act for Cameron LNG to site, construct and operate LNG export facilities to receive, store and regasify up to 2.33 Bcf/day in Cameron, La., and for Cameron Interstate Pipeline to construct a pipeline to transport natural gas to the Cameron LNG export facility. APGA filed a motion to intervene in opposition to this application with DOE. In its filing, APGA stated that the price increases that will occur as a result of LNG export will inhibit efforts to foster natural gas as a transportation fuel, which is important to wean the U.S. from its historic, dangerous dependence on foreign oil. Read the motion here.
  • On May 29, APGA submitted testimony to the House Committee on Small Business on how the proposed clarification to the definition of Waters of the United States (WOTUS) under the Clean Water Act (CWA) would impact our members, specifically highlighting our concerned about the potential impact on pipeline replacement work done by our members. Read the testimony here.
  • May 27, 2014 APGA filed a motion to intervene and protest Magnolia LNG, LCC's application in FE Docket No 13-132-LNG seeking long-term authorization to export approximately 1.08 Bcf/d of domestic natural gas as liquefied natural gas (LNG) by vessel to any county with which the United States does not have a free trade agreement requiring national treatment for trade in natural gas and LNG, that has, or in the future develops, the capacity to import LNG via ocean-going carrier, and with which is not prohibited by U.S. law or policy (non-FTA Nations). Read the motion here.
  • May 5, 2014 APGA filed a Motion for Leave to Intervene and Protest American Midstream, LLC's application to abandon some 355 miles of 16-22 inch diameter pipelines and associated laterals from the Desiard Compressor Station in Ouachita Parish, Louisiana to a point near Scottlandville in East Baton Rouge, Louisiana and related compressor stations, meter stations, and valve sites. the precedential effect of the Midla applications, if granted, could be far-reaching and harmful to gas-reliant communities throughout the nation. Read the Motion here.
  • On April 23, APGA filed written comments with the Environmental Protection Agency (EPA) commending EPA for proposing to ease reporting burdens under EPA’s Greenhouse Gas Reporting rule and suggesting changes to further reduce the burden to report estimated fugitive greenhouse gas emissions from distribution systems. Read the comments here.
  • April 14, 2014 APGA filed a Motion for Leave to Intervene and Protest with Respect to the Import and Export of Natural Gas to non-FTA Nations with Sabine Pass Liquefaction, LLC. Read the Motion here.
  • March 25, 2014 - Dave Schryver, Executive Vice President for the American Public Gas Association (APGA), will testify at a House Energy and Commerce Subcommittee on Energy and Power hearing to address H.R. 6, “H.R. 6, The Domestic Prosperity and Global Security Act”. APGA opposes all exports of LNG from the lower 48 states. The simple economics of supply and demand, along with every study that has been conducted on the subject, whether done by the federal government or by private consulting companies, all reach one conclusion: exports will increase the price of domestic natural gas. A copy of APGA’s testimony can be viewed here.
  • On February 28, APGA siled a motion to intervene in ConocoPhillips Alaska Natural Gas's petition to export Liquified Natural Gas (LNG). Read comments here.
  • On February 10, 2014 - APGA submitted comments on the Commodity Futures Trading Commission’s (“Commission”) “Position Limits for Derivatives,” 78 Fed. Reg. 75680 (December 12, 2013) (“Notice”) to Secretary Jurgens of Commodity Futures Trading Commission. Read the comments here.
  • On February 1, 2014 - APGA submitted comments to ASHRAE on their proposed addendum be to standard 189.1 – 2011 (first public review). It is the position of APGA that the entire premise for the ASHRE’s proposal is inconsistent with sound scientific principals and it lacked the necessary supporting documentation.  Read the comments here.
  • January 31, 2014 - Joint association letter to Federal Reserve System, Federal Deposit Insurance Corporation, and Office of the Comptroller of the Currency commenting on proposed October 2013 rule which incorporates certain international capital standards for banking institution as proposed by the Basel Committee on Banking Supervision (BCBS) - Read comments on Liquidity Coverage Ratio: Liquidity Risk Measurement, Standards, and Monitoring Federal Reserve System [Docket ID OCC-2013-0016] here.
  • January 30, 2014 - APGA submitted comments on the Proposed Determination of Hearth Products as a Covered Consumer Product issued by the Department of Energy (DOE) in this proceeding. Read the comments here.
  • January 6, 2014 - APGA submitted comments in response to the Rulemaking for Residential Furnace Fans Energy Conservation Standards, EERE-20-BT-STD-0011. APGA strongly supports the delineation of separate product classes for condensing and non-condensing furnace fans. Read the comments here.
  • 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.  Read the comments here.
  • 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. Read the comments here.
  • November 1, 2013 - APGA submitted comments with the Pipeline And Hazardous Materials Safety Administration (PHMSA) urging PHMSA to use caution before proceeding to modify or delete the concept of class location from its pipeline safety rules. Read the comments here.
  • 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. Read the comments here.
  • September 11, 2013 - U.S. Department of Energy (DOE) released an order (FE Docket 11-128-LNG) conditionally granting long term multi-contract authorization to export liquefied natural gas by vessel from the Cove Point LNG Terminal to Non-Free Trade Agreement nations. Read the order here.
  • 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. Read the comments here.
  • 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. Read the comments here.
  • 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. Read the Motion here.
  • 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 LLC. Read the Motion here.
  • 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. Read the comments here.
  • 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. Read the comments here.
  • April 22, 2013 - An amicus brief was filed with the U.S. Court of Appeals of the District of Columbia by the Commodity Markets Oversight Coalition (CMOC), a broad coalition of associations including APGA, in support of a Commodity Futures Trading Commission’s (CFTC) rule that would limit speculative trading in commodities. Read the amicus brief here.
  • 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). Read the comments here.
  • 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 government. Read the comments here.
  • March 19, 2013 - Testimony of Dave Schryver, APGA's Executive Vice President, before the House Committee on Oversight and Government Reform in advance of the hearing titled, The Department of Energy’s (DOE) Strategy for Exporting Liquefied Natural Gas (LNG). Read testimony here.
  • 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]). Read the comments here.
  • February 13, 2013 - Comments from the American Public Gas Association on Gas-Electric Coordination to FERC during their February 13 Technical Conference on Gas-Electric Coordination. Read the comments here.
  • 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”). Read the Protest here.
  • 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. Read the comments here.
  • February 12, 2013 - Testimony of the American Public Gas Association before the Senate Committee on Energy and Natural Resources Hearing “Opportunities and Challenges for Natural Gas” Click here for testimony.
  • 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. Read the comments here.
  • 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, Golden Pass Products LLC and Excelerate Liquefaction.
  • January 24, 2013 - Initial comments of the the American Public Gas Association in response to the 2012 LNG Export Study Read the comments here.
  • January 7, 2013 - APGA submitted response to Notice of Request by Federal Energy Regulatory Commission on the Coordination between Natural Gas and Electricity Markets. Read the comments here.
  • 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. Read the filing here.

 

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