INGAA appreciates the Commission’s efforts to chart a path forward to address the TCJA’s reduction in corporate income tax rates in a manner that is generally consistent with the ratemaking requirements of Sections 4 and 5 of the Natural Gas Act. The NOPR generally conforms to the prohibition against piecemeal ratemaking, recognizing that the Commission must evaluate all components of a pipeline’s cost of service before ordering a rate adjustment, as decreases in one cost component may offset increases in other cost components. The NOPR also acknowledges the importance of upholding freely-negotiated agreements between pipelines and shippers, including rate case settlements and negotiated rate service agreements. Nevertheless, INGAA believes that, as proposed, the NOPR must be significantly modified to allow pipelines a full and fair opportunity to recover their full revenue requirement
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