June 29, 2015 - APGA, INGAA, and AGA filed a request for clarification in the Coordination of the scheduling Processes of Interstate Natural Gas Pipelines and Public Utilities (Docket RM14-2-000) about the date interstate natural gas pipelines must implement the revised NAESB standards as required by Order No. 809. Read the comments here.
June 4, 2015 - APGA submitted comments to the Commodity Futures Trading Commission (CFTC) on their Notice of Proposed Rulemaking (NPR) to amend the trad option exemption under Part 30 of the Commission's rules. APGA supports proposed amendments to Part 32, 32.3(c), and Section 4s(e) while noting the same treatment should apply to capital charges. Read the comments here.
April 30, 2015 - APGA and the American Gas Association submitted a request to the Department of Energy for a 90-day extension in the comments period for DOE’s furnace NOPR. The current deadline for comments is June 10th. The letter requesting the extension (attached) makes several arguments as to why DOE should support the extension request. We will report back as soon as DOE provides a response. Read the request here.
March 27, 2015 - Opening statement of APGA Vice President Dave Schryver on the Department of Energy (DOE)'s proposed rule (NOPR) increasing natural gas furnace standards. APGA, whose members are predominantly located in southern tier states, is concerned that the NOPR, by eliminating non-condensing furnaces from the marketplace, is, among other things, taking away customer choice, discriminating against low-income persons, and precipitating fuel switching to less efficient energy alternatives – all to the detriment of the American public. Read the testimony here. APGA also submitted comments (here) on the NOPR under Docket EERE-2014-BT-STD-0031.
- March 25, 2015 - APGA signed on to the Natural Gas Council's comments in response to the Council on Environmental Quality’s (“CEQ”) revised draft guidance regarding the consideration of greenhouse gas (“GHG”) emissions and the effects of climate change in federal departmental and agency reviews under the National Environmental Policy Act (“NEPA”). The Natural Gas Council collectively represents segments along the entire natural gas value chain that produce, transport, deliver, and use clean, affordable, natural gas throughout the United States. Read the comments here.
- January 6, 2015 - APGA filed comments per the request for information (“RFI”) of the Department of Energy, Office of Energy Efficiency and Renewable Energy (“DOE”) published on October 31, 2014, 79 Federal Register (“FR”) 64,705 on Energy Conservation Program: Procedures, Interpretations, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products. APGA is especially concerned that such efficiency standards be adopted only after consideration of all relevant points of view, including the distributors of natural gas, whose desire for the efficient use of natural gas is matched only by their opposition to the adoption of standards that encourage fuel switching from equipment that relies on the cleanest of fossil fuels, natural gas, to equipment that, on a full fuel cycle basis, is both energy inefficient and environmentally unsound. Read the full comments here.
- December 1, 2014 - APGA filed written comments with the Pipeline and Hazardous Materials Safety Administration (PHMSA) opposing PHMSA’s proposed changes to its National Pipeline Mapping System (NPMS). APGA’s comments expressed concern with the potential cost of the revised reporting requirements and its impact on the usefulness of the online system. Read the comments to PHMSA here.
- December 1, 2014 - APGA joined a coalition letter to urge extension of the Section 179D tax deduction for energy efficient commercial and multifamily buildings, with the refinements to the provision included in S. 2260, the Expiring Provisions Improvement, Reform, and Efficiency (“EXPIRE”) Act of 2014. Section 179D expired on December 31, 2013. Read the letter here.
- November 28, 2014 - APGA also joined comments filed by the Natural Gas Council (NGC) to demonstrate to the Commission a united gas industry that supports retaining the 9am Gas Day start time. Read the NGC comments.
- November 26, 2014 - APGA filed comments with the banking regulators and CFTC in response to proposed a Notice of Proposed Rulemaking (NOPR) addressing margin requirements on uncleared swaps. The NOPR specifically exempts transactions with non-financial end-users from margin requirements which is a positive outcome for public gas systems. However, the NOPR would impose margin requirements on uncleared swap transactions between two swap dealers or major swap participants. The issue of concern for APGA is that a back to back swap transaction is a component of a prepay transaction. Read the comments to banking regulators. Read the comments to the CFTC.
- November 25th - APGA submitted comments to the Environmental Protection Agency’s on their proposed “Clean Power Plan for Existing Power Plants” rulemaking. APGA would like to make the following three recommendations to strengthen and improve the proposal: EPA should clarify that CHP and WHP at unaffected units are eligible compliance strategies for EGUs; Several modest changes are needed to ensure the Rule recognizes CHP's and WHP's benefits for affected units; and, EPA should provide guidance to states to enable them to most effectively incorporate CHP and WHP into their compliance plans to reduce emissions from unaffected units. Read the comments to the EPA.
- 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 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.