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Audit Matters INGAA Comments 11-22-05

INGAA suggests that there may be good cause for an audited company to move off of the shortened procedure track to trial-type procedures. INGAA requests that the… Read More

Gathering INGAA Comments 11-22-05

As a matter of law, companies that perform only a gathering function, whether they are independent or affiliated with an… Read More

Market Manipulation INGAA Comments 11-17-05

The Commission must apply its expertise and exercise discretion in applying securities and commodities… Read More

INGAA Answer to BP Ex Parte 11-17-04

INGAA requests that the Commission determine that INGAA’s letter does not constitute a prohibited off-the-record-communication… Read More

Storage-Infrastructure INGAA Comments 11-15-04

Studies by the INGAA Foundation as well as the National… Read More

CEII INGAA Comments 11-02-06

Pursuant to the Notice of Proposed Rulemaking issued September 21, 2006, the Interstate… Read More

Blanket Certificates INGAA Request for Rehearing 10-20-06

Pursuant to Rule 713(c)(1) and (2), the following is a specification of rehearing errors, along with the issues and law on which INGAA relies in this rehearing request: A. Noise Measurement. Whether the… Read More

AGA et al. v. FERC INGAA Motion to Govern 10-08-04

September 7, 2004, the Court granted the joint motion of Petitioners American… Read More

Blanket Certificates Joint NGSA INGAA Letter to Kelliher 9-19-06

Last November the Interstate Natural Gas Association of America (INGAA) and the… Read More

Storage Reporting INGAA Comments 9-10-04

Without storage data from the non-jurisdictional intrastate, LDC, and independent storage operators, which control almost one half the national inventory, there would be a substantial defect in the data base. In addition, daily storage data, unlike longer-term data, is vulnerable to significant and unrepresentative day-to-day fluctuations. Therefore, from the… Read More

Standards of Conduct INGAA Petition for Clarification 9-1-04

Pursuant to Rule 207(a)(5) of the Federal… Read More

Williston Discount INGAA Reply Comments 8-30-04

In general, the comments submitted confirm INGAA’s view that the CIG/Granite State policy is based on an unsupported presumption that shippers with discounted firm primary capacity are similarly situated with any… Read More

Blanket Certificates INGAA Comments 8-25-06

INGAA and NGSA petitioned the Commission in November 2005 to expand its blanket certificate… Read More

Williston Discount INGAA Motion to Intervene and Comments 8-9-04

In response to the decision of the United States Court of Appeals for the D.C. Circuit in Williston… Read More

ANR v. Louisiana Tax Commission INGAA Amicus Brief 7-2006

Louisiana’s attempt to circumvent the remedial obligation imposed by the due process clause presents a significant question that warrants review by this court: The decision conflicts with decisions of this court and other state appellate courts on a recurring question of substan-tial importance – the contours of the… Read More

Coordinating Federal Authorization INGAA Comments 7-31-06

Pursuant to the Notice of Proposed Rulemaking issued by the Federal… Read More

Reporting Regulations INGAA Comments 7-25-05

INGAA supports the Commission’s basic proposal to permit electronic filing of reports under §§ 260.9… Read More

Reporting Requirements INGAA Comments 7-9-06

In the short term, the Commission should tailor its proposed damage reporting proposal, as described… Read More

AGA et al. v. FERC INGAA Motion to Intervene 7-1-04

Pursuant to Rule 15(d) of the Federal Rules of Appellate Procedure, the Interstate… Read More

INGAA v. FERC INGAA Initial Brief 6-23-06

In its orders requiring pipelines to expense their Pipeline Safety Act costs, the… Read More