On April 11 INGAA filed comments in the PG&E and Coral Petitions regarding the Commission’s capacity release regulations. PG&E petitioned FERC to remove the price cap on released capacity transactions. Coral asked FERC to “clarify” various aspects of its capacity release regulations (see 3-07 Board Bulletin).
INGAA advocated that:
The Commission should lift the maximum rate cap for capacity release on the entire market (including primary short-term firm and interruptible transportation as well as capacity release), subject to monitoring and reporting requirements;
INGAA does not oppose Coral’s request to package/ tie pipeline capacity with gas supply, aggregating the releasing shipper’s capacity. INGAA, however, stated that it is not clear that the Commission lawfully can grant the relief Coral seeks through their clarification comments rather than through notice and rulemaking comments. INGAA advocated that, whatever it chooses to do, the Commission first needs to consider the value of a level playing field for the primary and secondary markets (it should not put the pipeline at a competitive advantage vis-à-vis its firm shippers); and that
The Commission should retain the shipper-must-have-title rule.
