APGA Filed Comments

  • 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.
  • On February 28, APGA filed a motion to intervene in ConocoPhillips Alaska Natural Gas's petition to export Liquified Natural Gas (LNG). Read the 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 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.
  • 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 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.
  • 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 - 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 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.
  • 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.
  • November 19, 2012 APGA Comments on Margin and Capitol Requirements for Covered Swap Entities to Federal Reserve, Federal Deposit Insurance Corporation, Comptroller of the Currency, Farm Credit Administration, and Federal Housing Finance Agency. Read letter here.
  • October 25, 2012 APGA Comments on the LEAK DETECTION STUDY – DTPH56-11-D-000001  criticizing a PHMSA draft report on pipeline leak detection (LDS) technology that erroneously concluded that LDS was feasible and cost effective for natural gas distribution piping systems. Read comments here and read the draft report from PHMSA.
  • October 15, 2012 Staff No-Action Relief: Temporary Relief from the De Minimis Threshold for Certain Swaps with Special Entities Read comments here.
  • October 9, 2012 APGA Comments on RESNET PDS 301-01  Draft Standard for the Calculation and Labeling of the Energy Performance of Low-Rise Residential Buildings using the HERS Index  You can read the comments here.
  • September 21, 2012  Extension of Comment Period, “Margin Requirements for Uncleared Swaps for Swap Dealers and Major Swap Participants,” 77 Fed. Reg. 41109  RIN 3038—AC97 (July 12, 2011). You can read the comments here.
  • August 17, 2012 Comments of the American Public Gas Association re: “Proposed Amendments to the Alternative Fuel Rule, (16 CFR part 309) (Matter No. R311002)” You can read the comments here
  • Comments from American Public Gas Association on July 27, 2012 on Regional Labeling for Heating and Cooling Equipment—Proposed Rule (16 CFR Part 305) (Project No. P114202) You can read the comments here.
  • On July 13, 2012, APGA submitted comments in response to the Building Performance Institute’s (BPI) proposed BPI-1100-T-2012: Home Energy Auditing Standard (formerly BPI-101). Comments of the American Public Gas Association here: general comment, additional comment, health & safety recommendation addtional comment, section 7 additional comment.
  • APGA files comments before Department of Transportation (DOT) on Pipeline Safety: Information Collection Activities, Excess Flow Valve Census Docket No. PHMSA–2012–0086 Comments of the American Public Gas Association here.
  • APGA files comments before Department of Transportation (DOT) on Pipeline Safety: Pipeline Damage Prevention Programs Docket No. PHMSA–2009–0192 Comments of the American Public Gas Association here
  • ASHRAE/IES Standard 100-2006R Comments from American Public Gas Association June 18, 2012 You can read the comments here.
  • ANSWER OF THE NATURAL GAS SUPPLY ASSOCIATION, THE INDEPENDENT PETROLEUM ASSOCIATION OF AMERICA, THE PROCESS GAS CONSUMERS GROUP, THE AMERICAN PUBLIC GAS ASSOCIATION AND THE AMERICAN FOREST AND PAPER ASSOCIATION TO REQUEST OF THE INTERSTATE NATURAL GAS ASSOCIATION OF AMERICA FOR RECONSIDERATION You can read the comments here.
  • American Public Gas Association submits its response to certain of the questions posed by Commissioner Moeller in his February 3, 2012 request for comments You can read the comments here.
  • Comments to FERC on procedures for filing and accessing privileged material and Critical Energy Infrastructure Information You can read the comments here.
  • Comments on Pipeline Safety: Miscellaneous Changes to Pipeline Safety Regulation You can read the comments here
  • COMMENTS OF THE AMERICAN PUBLIC GAS ASSOCIATION ON REGIONAL STANDARDS ENFORCEMENT FRAMEWORK DOCUMENT You can read the comments here
  • APGA Files Comments with the UNITED STATES DEPARTMENT OF TRANSPORTATION: Pipeline and Hazardous Materials Safety Administration PHMSA You can read the comments here
  • 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).  
  • 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 at DOE and OMB addressing DOE’s proposal to gather utility bill data to manage energy efficiency programs in the Office of Weatherization and Intergovernmental Programs (OWIP) July 1, 2011, APGA filed comments at DOE and OMB addressing DOE’s proposal to gather utility bill data to manage energy efficiency programs in the Office of Weatherization and Intergovernmental Programs (OWIP). If authorized by OMB under the Paperwork Reduction Act, DOE will be allowed to specify an evaluator to obtain grantee project site’s energy usage and cost (electricity and natural gas). A copy of APGA’s comments can be viewed on the APGA website 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.
  • APGA Submits Comments on Margin and Capital Requirements for Covered Swap Entities June 23, 2011 - The American Public Gas Association (“APGA”) appreciates filed comments on the Notice of Proposed Rulemaking on Margin and Capital Requirements for Covered Swap Entities (“Agency Proposal”) issued by the Office of the Comptroller of the Currency (“OCC”), the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Federal Deposit Insurance Corporation (“FDIC”), the Farm - 2 - Credit Administration (“FCA”), and the Federal Housing Finance Agency (“FHFA”) (collectively the “Agencies”). The Agency Proposal proposes joint rules to implement the margin and capital requirements under Section 731 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”),1 which added new Section 4s to the Commodity Exchange Act (“CEA”). Read them 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.
  • APGA Files Comments on ASHRAE/IES May 26, 2011 APGA filed comments on the proposed ASHRAE/IES Standard 100-2006R, Energy Efficiency in Existing Buildings. ASHRAE plays an important role in developing consensus standards on heating, ventilation, air conditioning and refrigeration. Such standards have been known to adversely impact the ability of natural gas to compete with electricity.
  • 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 comments with Department of Energy on National Energy Rating Program for Home 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.
  • 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 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.
  • APGA Files Comments with CFTC on position limits Click here to view the April 27, 2010 APGA comments filed with CFTC.
  • APGA Files Comments in response to Notice of Proposed Rulemaking Click here to view the October 26 2009 APGA comments filed with FERC.
  • 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.
  • 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 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.

 

 

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