INGAA submitted a response to questions posed by the Commission, along with comments on the petition for rulemaking to remove the cap on released capacity filed by Pacific Gas and Electric Company (PG&E) and Southwest Gas Company in RM06-21, and the petition for clarification of the capacity regulations riled by Coral Energy Resources, L.P., et al., in RM07-4.
In general, INGAA supports a more lighted-handed approach to regulation of the secondary market for released capacity. If the Commission proceeds in that direction, however, it should avoid creating a bifurcated or dual market for natural gas transportation under which “primary” capacity controlled directly by pipelines is subject to substantially different and more stringent rules than capacity controlled by “virtual pipelines” in the secondary release market. For the same reasons, the Commission should avoid imposing additional costs and burdens on pipelines, which remain responsible in many respects for administering the capacity release program.
INGAA urged the Commission to lift the cap on the entire market for short-term natural gas transportation and storage, and to reform its capacity release regulations in accordance with specific considerations discussed in the Comments.
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