Form 2 Initial Comments of the INGAA 3-28-07

Pursuant to the Commission’s “Notice of Inquiry” into the need for changes or revisions to its reporting requirements for financial forms issued February 15, 2007, submits comments principally directed at the Commission’s Form Nos. 2 and 2-A, “Annual Report for Major and Nonmajor Natural Gas Companies.”  Those forms are filed by INGAA’s interstate natural gas pipeline company members pursuant to 18 CFR §§ 260.1 and 260.2.

The comments set out INGAA’s views on the purpose of the Forms and their adequacy as presently constituted. The comments also address specific questions posed by the Commission

INGAA states that the Commission’s experience demonstrates that the information already available through Form 2 and the other periodic forms filed by pipelines, as well as the additional information that the Commission requires be made available by a pipeline on its website and elsewhere, is sufficient to provide the Commission and the public with all of the data necessary to evaluate a pipeline’s rate levels and determine whether further investigation under section 5 is prudent.  The “proper administration” of the Commission’s section 5 responsibilities is fully served by the Forms as they currently are constituted.