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All 2014 APGA Comments and Motions 

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APGA Comments_DOE_Furnace.pdf   217 KB   1 version
Uploaded - 07-12-2015
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.
 
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APGA Comments EERE-2013-BT-DET-0057.pdf   33 KB   1 version
Uploaded - 07-12-2015
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
 
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PFN Letter on LCR Propsal.pdf   53 KB   1 version
Uploaded - 07-12-2015
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)
 
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Comments on ASHRAE addendum be to standard 189_1-2011.pdf   124 KB   1 version
Uploaded - 07-12-2015
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.
 
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APGA Final Comment Letter Position Limits.pdf   87 KB   1 version
Uploaded - 07-12-2015
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
 
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APGA Protest_13-121-LNG - 041414.pdf   211 KB   1 version
Uploaded - 07-12-2015
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.
 
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052314_APGA Protest_13-132-LNG.pdf   187 KB   1 version
Uploaded - 07-12-2015
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)
 
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CP14-125 -126 Protest 050214.pdf   27 KB   1 version
Uploaded - 07-12-2015
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
 
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APGA comments on proposed EPA GHG reporting NOPR of 3-10-14.pdf   109 KB   1 version
Uploaded - 07-12-2015
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.
 
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APGA comments on proposed EPA3-10-14.pdf   109 KB   1 version
Uploaded - 07-12-2015
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.
 
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042312_11-162-LNG Filing.pdf   1.51 MB   1 version
Uploaded - 07-12-2015
June 19, 2014 - 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.
 
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APGA_MOI06_26_14_13_69_lng-c.pdf   2.82 MB   1 version
Uploaded - 07-12-2015
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”).
 
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APGA Comments_79Fed_Reg_32,261.pdf   821 KB   1 version
Uploaded - 07-12-2015
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).
 
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Comments on SNOPR FTC Labeling.pdf   128 KB   1 version
Uploaded - 07-12-2015
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.
 
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09 02 14 APGA Protest FE No 13-157-CNG-c.PDF   280 KB   1 version
Uploaded - 07-12-2015
September 2, 2104 - 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
 
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APGA13_153_lng 09_15_14-c.pdf   352 KB   1 version
Uploaded - 07-12-2015
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”). 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
 
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APGA Protest_092914_13-161-LNG-c.PDF   404 KB   1 version
Uploaded - 07-12-2015
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”).
 
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NCUC Filing.pdf   374 KB   1 version
Uploaded - 07-12-2015
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
 
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10_01_2014 AD14-19 Comments-c.pdf   40 KB   1 version
Uploaded - 07-12-2015
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 the measures 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).
 
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QER Comments.pdf   416 KB   1 version
Uploaded - 07-12-2015
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.
 
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Multi-Association-Comments-on-CHP-in-111d_10_27_2014_final.pdf   116 KB   1 version
Uploaded - 07-12-2015
October 27, 2014 - APGA joined with multiple energy associations to comment on the proposed Carbon Pollution Emissions Guidelines for Existing Stationary Sources: Electric Utility Generating Units, EPA-HQ-OAR-2013-0602, 79 Fed. Reg 34930 (June 18, 2014) to voice their support for combined heat and power (CHP) and waste heat to power (WHP) as valuable tools to reduce greenhouse gas emissions and offer recommendations to strengthen and improve the proposal.
 
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APGA Clean Power Plan Comments 11-25-2014.pdf   219 KB   1 version
Uploaded - 07-12-2015
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.
 
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APGA COMMENT TO CFTC ON MARGIN11_24_1.pdf   1.71 MB   1 version
Uploaded - 07-12-2015
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
 
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APGA COMMENT TO BANK REGULATORS ON MARGIN.pdf   1.73 MB   1 version
Uploaded - 07-12-2015
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.
 
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141128 NGC Comments RM14-2-000.pdf   74 KB   1 version
Uploaded - 07-12-2015
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
 
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APGA Comments on Revisions NPMS reporting.pdf   239 KB   1 version
Uploaded - 07-12-2015
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
 
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APGA Comments FE Docket No 13-155-LNG.PDF   217 KB   2 versions
Uploaded - 07-12-2015
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.
 
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