INGAA Reply Comments on FERC RM21-18

The Federal Energy Regulatory Commission (“Commission” or “FERC”) issued a Notice of Proposed Rulemaking on May 19, 2022 in the above-captioned docket (the “Proposed Rule”) that “proposes to establish a rule to require natural gas pipelines to submit all supporting statements, schedules and workpapers in native format (e.g., Microsoft Excel) with all links and formulas intact when filing a Natural Gas Act section 4 rate case.” On June 24, 2022, American Gas Association, American Public Gas Association, American Forest & Paper Association, Industrial Energy Consumers of America, Process Gas Consumers Group, and Natural Gas Supply Association (collectively “AGA, et al.”) filed comments requesting that the Commission modify its Proposed Rule to require that the rate model spreadsheets that are the subject of the Proposed Rule be filed as public (i.e., not as privileged) in all cases, without any ability to seek privileged treatment under Section 388.112 of the Commission’s regulations for any portion of the spreadsheets that the natural gas pipeline company treats as confidential for commercial reasons hereby respectfully moves for leave to file and files these Reply Comments in opposition
to AGA, et al.’s request.

Read the full comments here