Posted June 9, 2011

In these Reply and Supplemental Comments, the Interstate Natural Gas Association of America (INGAA) responds to the Joint Paries’ comments on a Federal Energy Regulatory Commission (Commission) Notice of Proposed Rulemaking (NOPR) concerning variable energy resources (VERs), Docket No. RM10-11-000.

INGAA takes issue with Joint Parties’ suggestion that natural gas pipelines’ scheduling and nomination procedures have impeded electric-gas integration, and that the Commission can and should consider scheduling and nomination procedures apart from the broader and more fundamental matters of cost causation and responsibility.

Interstate natural gas transmission pipelines are proud to support fully the growth of the electric power generation market, including any growth attributable to the expanded deployment and integration of VERs. INGAA’s members have supported and continue to supports efforts to discuss gas-electric integration issues, both within the Commission and outside it, in order to facilitate effective policies that recognize the needs of the gas and electric power industries and the integration of intermittent resources. Consistent with these principles, INGAA asks that when the Commission considers gas-electric integration issues, whether in this docket or elsewhere, the Commission recognize the continuing efforts of INGAA’s members to serve the unique needs of gas-fired electric generation and address the broad issues of cost causation and cost recovery inherent in providing that service. To limit the dialogue to nomination and scheduling timelines would unfairly narrow the discussion and omit the numerous and more important issues at stake.

These comments also supplement INGAA’s initial comments, which referenced a draft INGAA Foundation study that has since been released and is attached to these comments for inclusion in the public record.

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