On March 28, INGAA filed comments in response to FERC’s Notice of Inquiry regarding proposals to revise its financial reporting forms (2, 2-A, 3-Q). INGAA stated that the information currently in the forms, along with other publicly available information, is sufficient to provide FERC and the public with the data necessary to evaluate whether or not further investigation under section 5 is warranted. In support, INGAA pointed to the recent National Fuel and Southwest Gas proceedings. INGAA took the position that the forms serve to provide FERC and the industry with a snapshot of pipelines’ financial position during the reporting period and currently are not designed to facilitate projections or judgment calls based on the data “or to provide all of the information that may be useful to other agencies, the public, or to a litigant in challenging pipeline rates.” In evaluating proposals to increase reporting requirements, INGAA urged FERC to balance the amount and type of information it needs against the burden on the industry. INGAA reserved comments on specific proposals until they are fleshed out in comments by others.
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