Filings, Letters, and Testimonies Archives - INGAA https://ingaa.org/category/filings-letters-testimonies/ Thu, 08 Jun 2023 19:51:02 +0000 en-US hourly 1 https://wordpress.org/?v=6.1.1 https://ingaa.org/wp-content/uploads/2023/01/cropped-fav-32x32.png Filings, Letters, and Testimonies Archives - INGAA https://ingaa.org/category/filings-letters-testimonies/ 32 32 Natural Gas Council letter to Senate leadership on permitting reform https://ingaa.org/natural-gas-council-letter-to-senate-leadership-on-permitting-reform/ Tue, 02 May 2023 17:05:22 +0000 https://ingaa.org/?p=7477 May 1, 2023 The Honorable Joe Manchin ChairmanCommittee on Energy and Natural Resources304 Dirksen Senate Office BuildingWashington, C 20510 The Honorable John BarrassoRanking MemberCommittee on Energy and Natural Resources 304 Dirksen Senate Office BuildingWashington, DC 20510 The Honorable Tom Carper Chairman Committee on Environment and Public Works 410 Dirksen Senate Office BuildingWashington, DC 20510 The […]

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The Honorable Joe Manchin
Chairman
Committee on Energy and Natural Resources
304 Dirksen Senate Office Building
Washington, C 20510

The Honorable John Barrasso
Ranking Member
Committee on Energy and Natural Resources
304 Dirksen Senate Office Building
Washington, DC 20510

The Honorable Tom Carper
Chairman
Committee on Environment and Public Works
410 Dirksen Senate Office Building
Washington, DC 20510

The Honorable Shelley Moore Capito
Ranking Member
Committee on Environment and Public Works
410 Dirksen Senate Office Building
Washington, DC 20510

Dear Chairmen Manchin and Carper and Ranking Members Barrasso and Capito,

The Natural Gas Council, on behalf of the individuals and companies who produce, transport, and deliver natural gas across the nation, urges you to advance policies that would expedite permitting under key statutes by establishing clear timelines, clarifying the scope of agency review, and reducing the uncertainty associated with judicial review. Importantly, Congress can take these steps without compromising the United States’ environmental protections or our nation’s commitment to a clean-energy future.

Our critical infrastructure systems are fundamental to a reliable, secure, and affordable clean energy future. According to the Energy Information Administration, between 2005 – 2019, carbon dioxide emissions from the U.S. power sector declined by more than one-third while electricity generation increased roughly two percent, with fuel switching to natural gas accounting for more than half of those reductions. Natural gas also supports the growth of renewable energy by providing reliable, dispatchable fuel and storage that minimizes the risk of power disruptions during times of intermittent load. Therefore, expanding modern natural gas networks is essential to safely deliver energy to businesses and consumers while lowering greenhouse gas emissions.

Clear, predictable infrastructure permitting processes remain instrumental to achieving our shared energy, economic, security, and climate-related goals. Unfortunately, the current processes to site and approve new and expanded infrastructure remain cumbersome, often stalling projects for years with duplicative reviews, unnecessarily burdensome approvals, and unending legal challenges. These inefficiencies hamper access to domestic natural gas resources, creating reliance on imports, raising energy costs in certain regions, and, in the worst cases, limiting access to energy during periods of extreme weather.

To address these problems, Congress must reform the Clean Water Act (CWA) certification process to promote efficiency, properly scope state reviews and conditioning of permits, eliminate inconsistent results across agencies, and ensure that agencies use the process only to protect water quality, not pursue unrelated goals. Congress should also eliminate unnecessarily long and unduly burdensome National Environmental Policy Act (NEPA) reviews by clarifying agencies should only analyze reasonably foreseeable environmental effects causally related to the proposed project, focusing analyses on feasible alternatives, and establishing review schedules. Finally, Congress should end pointless, project-killing delays by establishing timelines for judicial review of CWA certifications and NEPA reviews and requiring a clear connection between the project and effects on water quality before a court can vacate a certificate and prolong the review process.

To fulfill America’s energy, economic, security, and climate-related goals, the Natural Gas Council and the companies we represent stand ready to work in a bipartisan manner to enact durable permitting provisions that enable development of the energy infrastructure needed to continue delivering the benefits of natural gas to the American people.

Sincerely,

Karen Harbert
President & CEO
American Gas Association

Frank Macchiarola
Senior Vice President
American Petroleum Institute

Amy Andryszak
President & CEO
Interstate Natural Gas Association of America

Jeff Eshelman
President & CEO
Independent Petroleum Association of America

Dena Wiggins
President & CEO
Natural Gas Supply Association

2023.05.01-NGC-permitting-letterDownload
]]> INGAA H.R. 1 Support Letter https://ingaa.org/ingaa-h-r-1-support-letter/ Fri, 31 Mar 2023 17:01:19 +0000 https://ingaa.org/?p=7459 March 21, 2023 The Honorable Kevin McCarthy Speaker of the HouseUnited States House of RepresentativesH-232, The CapitolWashington, DC 20515 The Honorable Hakeem JeffriesMinority LeaderUnited States House of RepresentativesH-204, The CapitolWashington, DC 20515 Dear Speaker McCarthy and Leader Jeffries, The Interstate Natural Gas Association of America (INGAA) writes in support of H.R. 1, Lower Energy Costs […]

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The Honorable Kevin McCarthy
Speaker of the House
United States House of Representatives
H-232, The Capitol
Washington, DC 20515


The Honorable Hakeem Jeffries
Minority Leader
United States House of Representatives
H-204, The Capitol
Washington, DC 20515

Dear Speaker McCarthy and Leader Jeffries,

The Interstate Natural Gas Association of America (INGAA) writes in support of H.R. 1, Lower Energy Costs Act, which would expedite permitting timelines and judicial reviews for energy infrastructure.
INGAA’s members represent most of the interstate natural gas transmission pipeline companies in the United States and Canada and operate approximately 200,000 miles of pipelines. These large capacity, critical infrastructure systems are integral to a reliable, secure, and affordable clean energy future. Maintaining a modern network of natural gas pipelines and storage facilities is essential to safely delivering energy to businesses and consumers while lowering greenhouse gas emissions.
Unfortunately, current federal permitting processes for new and expanded interstate natural gas pipelines remain cumbersome, often stalling projects for years with duplicative reviews, burdensome approvals, and unending legal challenges. Without bold and meaningful permitting reforms for interstate natural gas pipelines and related infrastructure, America will continue to struggle to meet its energy, economic, security and climate-related goals.

For these reasons, INGAA strongly endorses the Lower Energy Costs Act provisions that help reform federal permitting processes by clarifying that agencies may only analyze reasonably foreseeable environmental effects causally related to the proposed project, focusing NEPA analyses on feasible alternatives, and establishing agency and judicial review schedules. H.R. 1 also streamlines Clean Water Act certifications and associated scopes of review on federal permits. The proposal also would strengthen FERC’s primary permitting role on natural gas infrastructure, provide the agency authorization on cross-border pipeline applications and recognize the export of natural gas as being in the public interest.

INGAA stands ready to work in a bipartisan manner to enact these permitting provisions to enable the efficient and consistent development of energy infrastructure that will continue delivering the benefits of natural gas to the American people.

Sincerely,

Amy Andryszak
President & CEO
INGAA

2023.03.21 – INGAA HR 1 support letter (002)Download
]]> INGAA Letter to President Biden in response to Eversource letter on New England reliability concerns https://ingaa.org/ingaa-letter-to-president-biden-in-response-to-eversource-letter-on-new-england-reliability-concerns/ Mon, 07 Nov 2022 16:04:29 +0000 https://www.ingaa.org/ingaa-letter-to-president-biden-in-response-to-eversource-letter-on-new-england-reliability-concerns/ Dear President Biden: On behalf of the members of the Interstate Natural Gas Association of America, and to supplement the October 27 letter addressed to you by Eversource President & CEO Mr. Joseph R. Nolan Jr., I am writing to further underscore the concerns raised by Mr. Nolan about the New England region’s growing uneasiness […]

]]> Dear President Biden:

On behalf of the members of the Interstate Natural Gas Association of America, and to supplement the October 27 letter addressed to you by Eversource President & CEO Mr. Joseph R. Nolan Jr., I am writing to further underscore the concerns raised by Mr. Nolan about the New England region’s growing uneasiness about electric reliability and corresponding price spikes during cold winter months. I encourage your Administration to pursue a long-term solution that addresses the root cause of the region’s long-standing electric reliability problems—a lack of adequate natural gas infrastructure—rather than focus only on short-term, “emergency” solutions that were neither intended nor designed to address systemic issues like those present in New England.

Read the full letter here

39512 ingaa letter to president biden ne energy concerns 11.7.22Download
]]> INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities https://ingaa.org/ingaa-comments-on-ferc-nopr-on-cybersecurity-incentives-for-electric-utilities/ Mon, 07 Nov 2022 12:54:48 +0000 https://www.ingaa.org/ingaa-comments-on-ferc-nopr-on-cybersecurity-incentives-for-electric-utilities/ The Federal Energy Regulatory Commission (“Commission” or “FERC”) issued a Notice of Proposed Rulemaking (“NOPR”) and Notice Terminating Proceeding on September 22, 2022 in the above-captioned docket (the “Proposed Rule”) to “establish rules for incentive-based rate treatments for certain voluntary cybersecurity investments by utilities.” The Proposed Rule also terminates the NOPR proceeding in Docket No. RM21-3-000 […]

]]> The Federal Energy Regulatory Commission (“Commission” or “FERC”) issued a Notice of Proposed Rulemaking (“NOPR”) and Notice Terminating Proceeding on September 22, 2022 in the above-captioned docket (the “Proposed Rule”) to “establish rules for incentive-based rate treatments for certain voluntary cybersecurity investments by utilities.” The Proposed Rule also terminates the NOPR proceeding in Docket No. RM21-3-000 (December 2020 Cybersecurity Incentives NOPR). The Interstate Natural Gas Association of America (“INGAA”) respectfully submits these comments pursuant to the comment procedures set forth in the Proposed Rule.

As directed by the Infrastructure and Jobs Act (“IJA”), FERC proposes, under section 219A of the Federal Power Act, to incent electric utilities to make certain voluntary expenditures, that can either be capitalized costs or expenses, that materially enhance their security posture and to participate in cybersecurity threat information sharing programs. The Commission proposes a framework for (1) evaluating whether certain cybersecurity investments qualify for an incentive, including eligibility criteria to determine whether an investment is eligible for an incentive and use of a pre-qualified list (the “PQ List”) to identify the types of expenditures eligible for an incentive, (2) the type of incentive a utility could receive for an eligible cybersecurity expenditure, and (3) the duration and expiration conditions for incentives.

Read the full comments here

ingaa-comments-11-7-22-docket-rm22-19-002Download
]]> INGAA Incident Reporting Comments https://ingaa.org/ingaa-incident-reporting-comments/ Fri, 04 Nov 2022 11:59:23 +0000 https://www.ingaa.org/ingaa-incident-reporting-comments/ On March 11, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA or the Agency) published a Notice and Request for Comments seeking input on the Agency’s proposed revisions to the Annual and Incident Reporting forms and associated instructions (the Notice). The Interstate Natural Gas Association of America (INGAA) provides the following comments in response to […]

]]> On March 11, 2022, the Pipeline and Hazardous Materials Safety Administration (PHMSA or the Agency) published a Notice and Request for Comments seeking input on the Agency’s proposed revisions to the Annual and Incident Reporting forms and associated instructions (the Notice).

The Interstate Natural Gas Association of America (INGAA) provides the following comments in response to the proposed revisions to the Gas Transmission and Gathering Incident Report Instructions (the Instructions).

Read the full comments here

2022.5.10 ingaa incident reporting commentsDownload
]]> INGAA API Petition for Consideration of Gas Transmission Final Rule https://ingaa.org/ingaa-api-petition-for-consideration-of-gas-transmission-final-rule/ Fri, 04 Nov 2022 11:57:06 +0000 https://www.ingaa.org/ingaa-api-petition-for-consideration-of-gas-transmission-final-rule/ Pursuant to 49 C.F.R. § 190.335(a), the Interstate Natural Gas Association of America (INGAA) and the American Petroleum Institute (API) (the Associations) submit a Petition for Reconsideration (Petition) of the final rule issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued in Pipeline Safety: Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management […]

]]> Pursuant to 49 C.F.R. § 190.335(a), the Interstate Natural Gas Association of America (INGAA) and the American Petroleum Institute (API) (the Associations) submit a Petition for Reconsideration (Petition) of the final rule issued by the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued in Pipeline Safety: Safety of Gas Transmission Pipelines: Repair Criteria, Integrity Management Improvements, Cathodic Protection, Management of Change, and Other Related Amendments, (the Final Rule) published in the Federal Register on August 24, 2022.

Read the full comments here

2022.9.23-final-petition-of-ingaa-and-api-for-reconsideration-of-gas-transmission-final-rule-rin-2Download
]]> INGAA Comments on SEC Proposed Enhancement and Standardization of Climate-Related Disclosures for Investors https://ingaa.org/ingaa-comments-on-sec-proposed-enhancement-and-standardization-of-climate-related-disclosures-for-investors/ Fri, 04 Nov 2022 11:53:59 +0000 https://www.ingaa.org/ingaa-comments-on-sec-proposed-enhancement-and-standardization-of-climate-related-disclosures-for-investors/ The Interstate Natural Gas Association of America (“INGAA”) is a trade organization that advocates regulatory and legislative positions of importance to the natural gas pipeline industry. INGAA’s 26 members represent the majority of the interstate natural gas transmission pipeline companies in the United States, operating approximately 200,000 miles of pipelines and transporting more than 95% […]

]]> The Interstate Natural Gas Association of America (“INGAA”) is a trade organization that advocates regulatory and legislative positions of importance to the natural gas pipeline industry. INGAA’s 26 members represent the majority of the interstate natural gas transmission pipeline companies in the United States, operating approximately 200,000 miles of pipelines and transporting more than 95% of the nation’s natural gas to local gas distribution companies, manufacturing and industrial customers, gas marketers, liquified natural gas (“LNG”) export facilities, and gas-fired electric generators. Most of INGAA’s members are public companies or subsidiaries of public companies.

Read the full comments here

s7-10-22-ingaa-comments-on-proposed-climate-disclosure-rule-finalDownload
]]> INGAA Comments on Proposed Good Neighbor Plan https://ingaa.org/ingaa-comments-on-proposed-good-neighbor-plan/ Fri, 04 Nov 2022 11:51:27 +0000 https://www.ingaa.org/ingaa-comments-on-proposed-good-neighbor-plan/ The Interstate Natural Gas Association of America (“INGAA”), a trade association that represents 26 members of the interstate natural gas pipeline industry, is pleased to submit comments on the United States Environmental Protection Agency’s (“EPA” or the “Agency”) proposed “Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard” […]

]]> The Interstate Natural Gas Association of America (“INGAA”), a trade association that represents 26 members of the interstate natural gas pipeline industry, is pleased to submit comments on the United States Environmental Protection Agency’s (“EPA” or the “Agency”) proposed “Federal Implementation Plan Addressing Regional Ozone Transport for the 2015 Ozone National Ambient Air Quality Standard” (“Proposed Rule”). The Proposed Rule represents significant efforts on the part of the Agency to address interstate transport of nitrogen oxides (“NOx”) and the “significant contribution” of upwind states to downwind nonattainment and maintenance issues. INGAA has substantial experience addressing these issues and a track record of working with EPA to develop feasible and environmentally meaningful rules to address air quality.

Read the full comments here

final-ingaa-comments-on-proposed-good-neighbor-plan_6-21-22Download
]]> INGAA Comments on GHGRP https://ingaa.org/ingaa-comments-on-ghgrp/ Fri, 04 Nov 2022 11:48:50 +0000 https://www.ingaa.org/ingaa-comments-on-ghgrp/ The Interstate Natural Gas Association of America (INGAA), the trade association that represents the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection Agency’s (EPA or Agency) proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” (hereinafter, Proposed Rule), which was published […]

]]> The Interstate Natural Gas Association of America (INGAA), the trade association that represents the interstate natural gas pipeline industry, respectfully submits these comments in response to the United States Environmental Protection Agency’s (EPA or Agency) proposed “Revisions and Confidentiality Determinations for Data Elements Under the Greenhouse Gas Reporting Rule” (hereinafter, Proposed Rule), which was published in the Federal Register on June 21, 2022.

Read the full comments here

ingaa comments to proposed revision to 40 cfr 98_finalDownload
]]> INGAA AGA CWA 401 Comments https://ingaa.org/ingaa-aga-cwa-401-comments/ Fri, 04 Nov 2022 11:45:45 +0000 https://www.ingaa.org/ingaa-aga-cwa-401-comments/ The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the U.S. Environmental Protection Agency’s (“EPA” or “Agency”) proposal to revise and replace the Clean Water Act (“CWA”) Section 401 Certification Rule (“Proposed Rule”). Read the full comments here

]]> The Interstate Natural Gas Association of America (“INGAA”) and the American Gas Association (“AGA”) respectfully submit these comments in response to the U.S. Environmental Protection Agency’s (“EPA” or “Agency”) proposal to revise and replace the Clean Water Act (“CWA”) Section 401 Certification Rule (“Proposed Rule”).

Read the full comments here

2022.08.08-ingaa-aga-cwa-401-comments-w-attachmentsDownload
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