Program areas at INGAA
Regulatory/environment:ingaa developed and advocated for proposed revisions to nepa, cwa section 401, nationwide permits, social cost of ghgs, and other applicable federal regulations. Ingaa actively engages with the federal energy regulatory commission and filed extensive comments in response to proceedings related to updates to the certificate policy statement, proposed duty of candor rule, inquiry into treatment of trade association dues, and an inquiry on whether pipelines should be able to "tie" separate, non-contiguous segments of capacity. Ingaa continued to engage in litigation where precedential questions or regulations affecting Interstate Natural Gas pipelines are at stake including filing an amicus brief in spire stl's section 7 certificate and litigating the district court's decision to vacate the 2020 cwa 401 in the 9th circuit court of appeals. Ingaa developed, issued, promoted an association position and commitments related to climate change. Ingaa filed comments in multiple environmental rulemakings including related to cwa 401 rule, epa methane rule, epa good neighbor proposal, epa ghgrp, and sec climate proposal. Ingaa participates in initiatives with industry groups and the federal government to enhance the physical and cyber security of Natural Gas pipelines. This includes participation in the oil and Natural Gas sector coordinating council and partnership with the downstream Natural Gas isac. Accordingly, ingaa filed comments in rulemakings related to the nist cybersecurity framework, sec cybersecurity disclosures, cisa's rfi on cyber incident reporting for critical infrastructure act.
Safety:ingaa actively engages with the pipeline and hazardous materials safety administration. Notably, ingaa submitted a petition for reconsideration on phmsa's final fas transmission rule. Ingaa also engaged in the drafting/facilitating input into three industry recommended practices api 1170, api rp 1171 and api rp 1185.
Legislative:ingaa supports legislative policies that promote the development of Natural Gas infrastructure, and the safe, efficient operation of Natural Gas pipelines. Ingaa joined with other like-minded stakeholders in advocating these policies to the u.s. congress. Specifically, ingaa advocated for meaningful permitting reform legislation.