The Interstate Natural Gas Association of America (“INGAA”) moves to intervene in this proceeding and submits the following comments in protest of the petition for rulemaking (“Petition”) that the American Gas Association, the American Public Gas Association, the Process Gas Consumers Group, and the Natural Gas Supply Association (collectively, “Petitioners”) filed with the Federal Energy Regulatory Commission (“Commission” or “FERC”) on June 2, 2022.
I. EXECUTIVE SUMMARY
For 23 years, shippers and their trade organizations, including, at times, Petitioners, have complained that the practice of offering multiple non-contiguous segments of capacity at auction is unjust, unreasonable, and unduly discriminatory.2 For 23 years, “the Commission has repeatedly rejected arguments that the aggregation of bids is anti-competitive” and permitted “packaging noncontiguous segments of capacity, so long as shippers are not required to bid on segments of capacity that are not desired and therefore have an opportunity to obtain the portion of the capacity they seek.”3 This policy is consistent with the Commission’s long-standing position that “[m]aximizing revenue and the use of pipeline capacity will benefit all customers by increasing billing determinants and thereby lowering unit fixed costs in the next rate case.”
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