Regulatory Submissions

All 2012 APGA Federal Comments and Motions 

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APGA Waiver Comments 020612.pdf   553 KB   1 version
Uploaded - 07-11-2015
February 6 2012 - COMMENTS OF THE AMERICAN PUBLIC GAS ASSOCIATION ON REGIONAL STANDARDS ENFORCEMENT FRAMEWORK DOCUMENT
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MTIP FE Docket No_ 11-128-LNG_stamped.pdf   1.83 MB   1 version
Uploaded - 07-12-2015
February 6, 2012 - MOTION FOR LEAVE TO INTERVENE AND PROTEST OF AMERICAN PUBLIC GAS ASSOCIATION BEFORE DOE. Pursuant to Sections 590.303 and 590.304 of the Administrative Procedures with Respect to the Import and Export of Natural Gas.
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02_27_2012 APGA MTI and Comments.pdf   821 KB   1 version
Uploaded - 07-12-2015
February 27, 2012 - APGA Files Motion to Intervene in DOE Application for Export from Carib Energy LLC. Pursuant to Sections 590.303 and 590.304 of the Administrative Procedures with Respect to the Import and Export of Natural Gas,l the American Public Gas Association ("APGA") files this motion to intervene and comments in the above captioned proceeding.
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APGA RM12-2 Comments.pdf   36 KB   1 version
Uploaded - 07-11-2015
February 27 2012 Comments to FERC on procedures for filing and accessing privileged material and Critical Energy Infrastructure Information You can read the comments
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APGA AD12-12 Comments 033012.pdf   28 KB   1 version
Uploaded - 07-11-2015
March 30 2012 American Public Gas Association submits its response to certain of the questions posed by Commissioner Moeller in his February 3, 2012 request for comments
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Answer to INGAA Reconsideration.pdf   29 KB   1 version
Uploaded - 07-11-2015
April 16 2012 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
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APGA comments on 4-2-12 damage prevention NOPR 7-9-12.pdf   74 KB   1 version
Uploaded - 07-11-2015
April 2 2012 APGA files comments before Department of Transportation (DOT) on Pipeline Safety: Pipeline Damage Prevention Programs Docket No. PHMSA–2009–0192
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Petition for Clarification - Special Entity Sub-Threshold.pdf   140 KB   1 version
Uploaded - 07-12-2015
May 2, 2012 - Petition For Clarification Of, Or Exclusion From, Application Of The “Special Entity Sub-Threshold” In The De Minimis Exception To The “Swap Dealer” Definition For “Utility Operations-Related Swaps” To Which “Utility Special Entities” Are A Party. Petition for an order clarifying, or granting an exclusion from, application of the $25 Million “Special Entities Sub-Threshold” in the de minimis exception to the CFTC’s definition of “Swap Dealer” for “Utility Operations-Related Swaps” entered into by “Utility Special Entities.” The Utility Operations-Related Swaps would remain subject to the overall $3 Billion De Minimis Threshold applicable to swap dealing activities (and to the $8 Billion De Minimis Threshold applicable during the Phase-In Period).
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Brief Final.pdf   1.48 MB   1 version
Uploaded - 07-12-2015
May 14, 2012 - APGA Files a brief with the US Court of Appeals for the District of Columbia Circuit against UNITED STATES DEPARTMENT OF ENERGY, RESPONDENT AIR CONDITIONING CONTRACTORS OF AMERICA, ET AL., INTERVENORS
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APGA comments on 5-15-12 EFV census 7-16-12.pdf   80 KB   1 version
Uploaded - 07-11-2015
May 15 2012 APGA files comments before Department of Transportation (DOT) on Pipeline Safety: Information Collection Activities, Excess Flow Valve Census Docket No. PHMSA–2012–0086
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ASHRAE-IES Standard 100-2006R 6 18 12 comments.pdf   23 KB   1 version
Uploaded - 07-11-2015
June 18, 2012 ASHRAE/IES Standard 100-2006R Comments from American Public Gas Association
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Associations Boardwalk Intervention re Credits.pdf   24 KB   1 version
Uploaded - 07-12-2015
July 3, 2012 - MOTION FOR LEAVE TO INTERVENE OF THE NATURAL GAS SUPPLY ASSOCIATION, THE INDEPENDENT PETROLEUM ASSOCIATION OF AMERICA, THE PROCESS GAS CONSUMERS GROUP, AND THE AMERICAN PUBLIC GAS ASSOCIATION
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BPI_Comment_Form - APGA - General.pdf   180 KB   1 version
Uploaded - 07-11-2015
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
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BPI_Comment_Form - APGA - 7_20-21.pdf   177 KB   1 version
Uploaded - 07-11-2015
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: additional comment
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BPI_Comment_Form - APGA - H&S.pdf   177 KB   1 version
Uploaded - 07-11-2015
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: health & safety recommendation additional comment
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BPI_Comment_Form - APGA - Section 7.pdf   182 KB   1 version
Uploaded - 07-11-2015
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: section 7 additional comment.
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Intervention and Rehearing in ANR and Trunkline.pdf   39 KB   1 version
Uploaded - 07-12-2015
July 23, 2012 - MOTION FOR LEAVE TO INTERVENE OUT-OF-TIME AND REQUEST FOR REHEARING 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 & PAPER ASSOCIATIO
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Matter No R311002.pdf   154 KB   1 version
Uploaded - 07-12-2015
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)”
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FTC Label Comments _P114202_ - APGA.pdf   15 KB   3 versions
Uploaded - 07-12-2015
July 27, 2012 on Comments from American Public Gas Association on Regional Labeling for Heating and Cooling Equipment—Proposed Rule (16 CFR Part 305) (Project No. P114202) Y
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Request for No-Action Relief.pdf   266 KB   1 version
Uploaded - 07-12-2015
October 7 2012 - APGA, APPA, LPPC, TAPS, and BPA filed a request for Interim No-Action Relief until the Commission Takes Final Action on Petition for Rulemaking to Amend Commission Rule
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APGA Comments on RESNET PDS 301.pdf   15 KB   1 version
Uploaded - 07-12-2015
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
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No Action Letter - special entity de minimis.pdf   124 KB   1 version
Uploaded - 07-12-2015
October 15, 2012 No-Action Relief: Temporary Relief from the De Minimis Threshold for Certain Swaps with Special Entities
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APGA comments on leak detection study 10-25-12.pdf   278 KB   1 version
Uploaded - 07-12-2015
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
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PHMSA Leak Detection study draft oct 2012.pdf   3.69 MB   1 version
Uploaded - 07-12-2015
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 the draft report from PHMSA.
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12-77-LNG-Protest.pdf   955 KB   1 version
Uploaded - 07-12-2015
November 2, 2012 - APGA files Motion for Leave to Intervene and Protest pursuant to sections 590.303 and 590.304 of the Administrative Procedures with Respect to the Import and Export of Natural Gas.
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102184431-v4-APGA.pdf   163 KB   1 version
Uploaded - 07-12-2015
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
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FE Docket No 12-100-LNG (2).pdf   4.41 MB   1 version
Uploaded - 07-12-2015
December 12, 2012 - APGA files motion for leave to intervene and protest of the APGA pursuant to Sections 590.303 and 590.304 of the Administrative Procedures with Respect to the Import and Export of Natural Gas.
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APGA AD12-12 Comments 010713.pdf   31 KB   1 version
Uploaded - 07-12-2015
March 30 2012 American Public Gas Association submits its response to certain of the questions posed by Commissioner Moeller in his February 3, 2012
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APGA Final Comments on Margin Requirements.pdf   62 KB   1 version
Uploaded - 07-12-2015
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APGA Protest 12-97-LNG 122612.pdf   1.04 MB   4 versions
Uploaded - 07-12-2015

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