Filings, Letters, and Testimonies

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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

Section 1813 Native American Rights-of-Way INGAA Comments 9-3-06

The Interstate Natural Gas Association of America (INGAA) submits the following comments on… 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

CZMA INGAA Comments on NOAA Proposal 8-25-03

Pursuant to the proposed rule issued in the referenced proceeding on June 11, 2003, 1 the Interstate… 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

Petal v. FERC INGAA Motion to Intervene 6-22-04

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

Natural Gas Interchangeabiltiy INGAA Comments 6-9-05

A. Implementation of the NGC+ White Papers Nationwide standards for… Read More

Natural Gas Interchangeability INGAA AGA Joint Statement 6-2-06

As a result of discussions among the Interstate Natural Gas Association of America… Read More

Underground Storage INGAA Comments 5-31-06

Pursuant to the notice of proposed rulemaking (… Read More

ETariff INGAA Comments 5-30-06

All of INGAA’s members agree that the Commission’s eTariff proposal cannot be implemented in its… Read More

Creditworthiness INGAA Reply Comments 5-28-04

INGAA requests that the Commission, in its final rule, not require pipelines to accept surety… Read More