INGAA comments on annual charge filing procedures RM12-14


The Federal Energy Regulatory Commission (FERC or Commission) is proposing to amend its regulations at 18 C.F.R. § 154.402 to revise the filing requirements for natural gas pipelines that choose to recover Commission-assessed annual charges through an annual charge adjustment (ACA) clause. The Commission is proposing to eliminate the annual filing requirement to reflect a revised ACA unit charge authorized by the Commission for each fiscal year. In its place, the Commission proposes to require pipelines to make a one-time compliance filing to incorporate into their tariffs the Commission-authorized ACA unit charge by referencing the FERC’s website.

INGAA is supportive of the Commission’s proposal and appreciates the Commission’s continued efforts to reduce regulatory filing burdens on pipelines.  INGAA, however, noticed that the time gap between the Final Rule’s compliance filing date and the October 1, 2013 tariff record effective date could cause an additional, unintentional filing burden on both pipelines and the Commission, as well as cause a pipeline and its customers unnecessary confusion as to the currently effective pipeline tariff and rates. INGAA offers a possible solution in its comments.