On April 30 INGAA filed reply comments in Docket No. RM07-1, Standards of Conduct for Transmission Providers. INGAA requested that the Commission issue a final rule adopting the Interim Rule, modified as requested by INGAA in its Initial Comments.
In its reply comments, INGAA stated that the record lacks any evidence that would support an extension of the Standards of Conduct to non-Marketing Affiliates, affiliated power marketers of natural gas transmission providers or to Marketing Affiliates of affiliated transmission providers. Further, INGAA asserted that other commenters had not supported the need to extend the Standards of Conduct to asset managers or agents. INGAA asserted that to the extent that an asset manager sells or brokers gas and holds or controls capacity on their affiliated pipeline, they should fall within the definition of a Marketing Affiliate. INGAA also stated that the Commission should not require pipelines to post discretionary acts under their FERC approved tariffs. Finally, INGAA stated that under the Natural Gas Act, Standards of Conduct cannot apply until a pipeline commences transportation service.