On April 2, 2012, INGAA filed a Petition Requesting the Commission Adhere To Its Existing Rules, Regulations and Procedures with the Federal Energy Regulatory Commission (FERC). INGAA requested the Commission should definitively reaffirm that no right-of-way or work space limitations apply to auxiliary installations under the plain reading of Section 2.55(a) of the Commission’s regulations. If the Commission wishes to consider amending Section 2.55(a) to add such limitations for some or all of the installations included under Section 2.55(a), the Commission may do so only through notice and comment rulemaking in compliance with the letter and the spirit of the President’s executive orders and the specific requirements of the APA. If a rulemaking is initiated, the Commission should state that it will not seek to enforce any change to Section 2.55(a) until it has completed any rulemaking process it might initiate.
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