Motion for Leave to Answer and Answer of INGAA to February Filings by APGA and Petitioners

The Interstate Natural Gas Association of America (“INGAA”), pursuant to Rules 212 and 213 of the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) Rules of Practice and Procedure, moves for leave to answer and answers the filings made by American Public Gas Association (“APGA”) and Petitioners on February 16, 2018 and February 20, 2018, respectively. Although the Commission’s procedural rules generally do not allow for answers to answers, the Commission may permit them for good cause. The Commission has accepted answers that facilitate the decisional process or aid in the explication of issues, and has explained that it will accept answers that “assist[] in our decision-making process.” INGAA requests that the Commission accept this answer to clarify the record and address inconsistencies in Petitioners’ recent pleadings.

Download the full filing here.