Pursuant to the Notice issued October 2, 2017 by the Federal Energy Regulatory Commission (FERC or the Commission) in response to the Department of Energy (DOE) direction on September 28, 2017, under Section 403 of the Department of Energy Organization Act that FERC consider a notice of proposed rulemaking (NOPR or Proposed Rule), the Interstate Natural Gas Association of America (INGAA) respectfully submits these reply comments.
INGAA is a trade organization that advocates regulatory and legislative positions of importance to the natural gas pipeline industry in North America. INGAA’s 26 members represent the majority of the interstate natural gas transmission pipeline companies in the United States. Its United States members are regulated by the Commission pursuant to the Natural Gas Act (NGA), 15 U.S.C. §§ 717-717w. INGAA’s members, which operate approximately 200,000 miles of pipelines, serve as an indispensable link between natural gas producers and consumers.
The NOPR is fatally flawed, and should not be the basis for any rule by FERC. Instead, the Commission should direct all regional transmission organizations (RTOs) and independent system operators (ISOs) to examine whether, and if so how, they value reliability and resilience in wholesale electricity markets and report their findings to the Commission within 90 days.