Regulatory Submissions

On June 20, APGA submitted comments as part of a coalition of industry trade associations in response to the Office of Management and Budget’s (OMB) Administration’s proposed changes to OMB Circular A-4, which provides guidance to all federal agencies on how to conduct cost-benefit analyses for rulemakings.

These proposed changes, paired with Executive Order 12866 (Regulatory Planning and Review), are of utmost importance to APGA and its members because of its potential impact on regulations coming out of Pipeline and Hazardous Materials Safety Administration (PHMSA), Federal Energy Regulatory Commission (FERC), Department of Energy (DOE), and all other federal agencies.  If finalized, federal agencies would be provided with an unprecedented level of deference, which would lessen the burden for them to promulgate rules that would have otherwise been limited by excessive costs.  For more background on these proposed changes, please see an earlier community post here.

Earlier, APGA joined the same coalition in submitting comments in response to OMB’s proposed changes to the public engagement process for rulemakings currently under review by the agency.

APGA would like to thank its members – including Middle Tennessee, the Municipal Gas Authority of Georgia, and Jackson Energy Authority – that submitted their own comments.