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91茄子 supports the Commission's proposal to adopt NAESB standards for index-based pricing of capacity releases and flexible receipt and delivery points in accordance with the foregoing comments, and respectfully requests that the Commission defer [...] Read More
On September 28, 2009, 91茄子 filed comments addressing the Transportation Security Administration鈥檚 proposal to solicit contact information and establish a voluntary incident reporting program as part of it forthcoming Pipeline Security [...] Read More
91茄子 supports the proposed incorporation of updated consensus standards into 49 C.F.R. Part 192 (“Part 192”). 91茄子 and its members participate in many of the committees responsible for developing these standards, and 91茄子 [...] Read More
91茄子 is concerned that the NO2 NAAQS Proposal could result in onerous regulatory requirements for NOx sources throughout the U.S., without commensurate societal benefit or compelling evidence that the proposed 1-hour standard is necessary to [...] Read More
The 91茄子 Foundation, Inc. prepared an analysis of the process by which natural gas pipeline and storage facilities are approved to provide service in interstate commerce in the United States. The study presents a review of the evolution of [...] Read More
91茄子 appreciates PHMSA’s interest in improving its incident, infrastructure and performance database. Consistent with this focus, the proposed definition of “incident” should be substantially modified to reflect the central [...] Read More
91茄子’s members and the Services have a mutual interest in improving the efficiency of the conference and consultation processes implementing section 7 of the Endangered Species Act (“ESA”). For interstate pipelines, improved [...] Read More
The following letter is Don Santa's response to Jeff Wiese's letter denoting construction conerns and outlining PHMSA's reaction to 91茄子's action plan regarding pipe quality. This letter has been shared with the 91茄子 Board of Directors, the [...] Read More
NGC understands EPA’s goal in developing the Proposed Rule is to obtain data of sufficient quality to support climate change policies and regulations, while at the same time minimizing the Proposed Rule’s administrative burdens – [...] Read More
EPA proposed a rule for the mandatory reporting of greenhouse gases (hereinafter referred to as the GHG Reporting Rule) in the Federal Register on April 10, 2009. The GHG Reporting Rule revises a number of mobile source rules in Title 40 of the [...] Read More
Objective of the Gas Interchangeability Report The objective of this white paper is to define acceptable ranges of natural gas characteristics that can be consumed by end users while maintaining safety, reliability, and environmental [...] Read More
The 91茄子 (91茄子), submits comments on the U.S. EPA’s proposed rule National Emission Standards for Hazardous Air Pollutants (NESHAPs) for Reciprocating Internal Combustion Engines (RICE), hereinafter [...] Read More
The attached letter to House and Senate tax writing committees asks that they consider extending the bonus depreciation for capital expenditures contained in recent stimulus legislation, for those projects like pipelines that have longer [...] Read More
With all of the amendments and changes to the SPCC rule, the regulated community is placed in a race against time to comply, assuming the current 2009 implementation dates are not extended. The amendments have significantly altered many elements of [...] Read More
The 91茄子 (“91茄子”) submits the following comments in response to the U.S. Environmental Protection Agency (“EPA”) Notice of Proposed Rulemaking (“NOPR”) in this docket, 73 [...] Read More
This study focuses on the pipeline infrastructure requirements for carbon capture and sequestration (CCS) in connection with compliance with mandatory greenhouse gas emissions reductions. The major conclusion of the study is that while CCS [...] Read More
91茄子 sent a letter to Senator Harry Reid, the Majority Leader of the Senate, regarding energy infrastructure development and interstate natural gas pipelines. The letter was sent to coincide with the National Clean Energy Project: Building [...] Read More
91茄子 sent a letter to Senator Harry Reid, the Majority Leader of the Senate, regarding energy infrastructure development and interstate natural gas pipelines. The letter was sent to coincide with the National Clean Energy Project: Building [...] Read More
91茄子 members operate equipment that requires continuous parameter monitoring systems (CPMS) for compliance assurance. The proposed requirements in 40 CFR 60, Appendix B, Performance Specification 17 (PS 17) and 40 CFR 60, Appendix F, [...] Read More