Form 2 INGAA Comments 11-13-07

INGAA submits the following comments on the Commission’s Notice of Proposed Rulemaking to amend its forms, reports and statements for natural gas companies (i.e., Forms 2, 2-A, and 3-Q). The Commission’s proposal will require INGAA’s interstate natural gas pipeline members to provide additional and more detailed information regarding their sources of revenue and amounts included in rate base, and to identify costs related to affiliate transactions, incremental facilities, and discounted and negotiated rates. 

In general, INGAA does not object to the Commission’s proposed changes.   While INGAA has a concern related to the timing of the final rule and the burdens that may result due to the need for midyear accounting modifications, INGAA’s substantive comments are confined to two discrete issues: INGAA requests that the Commission (1) reconsider removing the $250,000 threshold for reporting unaffiliated outside professional and consultative services, and (2) revise the proposed requirements for new pages 521a and 521b regarding quarterly reporting of shipper-supplied gas.  INGAA submits that amending the Commission’s proposals to address these two relatively minor issues will preserve the integrity of the Commission’s overall goals while avoiding unnecessary and unreasonable reporting burdens.