Standards for Business Practices INGAA Reply Comments 3-14-05

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.212 (2004), the Interstate Natural Gas Association of America (“INGAA”) hereby moves for leave to file reply comments to certain parties and hereby submits those reply comments. INGAA is a non-profit trade association that represents virtually all of the major interstate and inter-provincial natural gas pipeline companies operating in the United States, Canada, and Mexico. INGAA’s United States members, which account for over 90 percent of all natural gas transported and sold in domestic interstate commerce, are regulated by the Commission pursuant to the Natural Gas Act (“NGA”), 15 U.S.C. §§ 717-717w.