INGAA Foundation
INGAA submits comments and filings to various regulatory, congressional and administrative entities.
Electronic Tariff Filings INGAA Supplemental NOPR COmments 5-29-08 RM01-5
Submitted: 05/29/2008
INGAA requests that the Commission: (1) not impose a definite implementation date at this time to allow time for software development and testing, and continue to provide a testing site after implementation; (2) provide alternate procedures or a waiver of regulations in the event of an electronic system failure; and (3) clarify that interested parties may comment only on matters related to tariff revisions that are “appropriately ... More>>
Standards of Conduct INGAA Appendix to Comments 5-12-08 RM07-1
Submitted: 05/12/2008
The appendix, in particular, is designed to show the reader, using the Word program’s redline/strikeout feature, the difference between the regulatory text proposed by the Commission in it's Notice for Proposed Rulemaking, and the changes to that text that INGAA is proposing in its comments. Please see Standards of Conduct INGAA Comments 5-12-08 RM07-1 for a more detailed description of INGAA's position. More>>
Pipeline Posting Requirement INGAA Comments 3-18-08 RM08-2
Submitted: 03/13/2008
INGAA requests the Commission retract the NOPR’s proposed amendment of 18 C.F.R. § 284.13(d), and thereby refrain from requiring interstate pipelines to post daily actual flows. Should the Commission instead go forward with an actual flow reporting requirement, INGAA requests the Commission revise its proposed regulations to not require the installation of new facilities; to categorically exclude mainline segment reporting; to ... More>>
Proxy Group INGAA Post-technical Conference Supplemental Workpaper 3-12-08
Submitted: 03/12/2008
Attached to the Interestate Natural Gas Association of America (“INGAA”)'s post-technical conference supplemental comments is an affidavit of its witness, Dr. Michael J. Vilbert, in response to the Reply Comments of the State of Alaska. Dr. Vilbert’s affidavit, Table 1, references a workpaper. More>>
General Conformity Regulations, 73 Fed. Reg. 1402
Submitted: 03/10/2008
The Clean Air Act (CAA) general conformity provisions state that: No department, agency or instrumentality of the Federal Government shall engage in, support in any way or provide financial assistance for, license or approve any activity which does not conform to a [CAA] state implementation plan [SIP] after it has been approved or promulgated. CAA §176(c)(1). Section 176(c)(1) goes on to say that “conformity” requires ... More>>
Proxy Group INGAA Post-Technical Conference Comments 2-11-08
Submitted: 02/12/2008
These comments reinforce INGAA's position that the Commission’s use of GDP for the long-term growth variable of the Discounted Cash Flow methodology produces reasonable results and should be retained. More>>
Capacity Release INGAA Comments 1-25-08
Submitted: 01/25/2008
On January 25, INGAA filed comments on the Commission’s notice of proposed rulemaking in which it proposed to lift the maximum rate cap on short-term capacity release transactions and relax the tying prohibition and bidding requirements to facilitate asset management agreements (AMAs). LDCs and other major pipeline shippers employ AMAs to manage their capacity holdings efficiently. INGAA agreed in general with FERC's proposed ... More>>
U.S. Environmental Protection Agencies' and U.S. Army Corps of Engineers’ Guidance Regarding Clean Water Act Jurisdiction After Rapanos
Submitted: 01/21/2008
The natural gas pipeline industry constructs new pipelines in hundreds of acres of wetlands annually and conducts maintenance operations in approximately 2,800 acres of wetlands. These projects also cross hundreds of thousands of tributaries and streams in a given year. These activities require permitting and mitigation, typically under the Clean Water Act, 33 U.S.C. §§ 1251 et seq ., including permits under sections 402 and 404 and ... More>>
Proxy Group INGAA Long-term Growth Comments 12-21-07
Submitted: 12/21/2007
In response to the Commission’s “Notice of Technical Conference and Request for Additional Comments,” [1] issued on November 15, 2007, the Interstate Natural Gas Association of America (“INGAA”) hereby submits the following additional comments on the long-term growth component of the Commission's DCF model. Attached is an analysis prepared by Michael J. Vilbert of the Brattle Group. Mr. Vilbert has ... More>>
Form 2 INGAA Comments 11-13-07
Submitted: 11/13/2007
INGAA submits the following comments on the Commission’s Notice of Proposed Rulemaking to amend its forms, reports and statements for natural gas companies (i.e., Forms 2, 2-A, and 3-Q). The Commission’s proposal will require INGAA's interstate natural gas pipeline members to provide additional and more detailed information regarding their sources of revenue and amounts included in rate base, and to identify costs ... More>>