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Transparency INGAA Request for Rehearing 12-22-08 RM08-2

  When it issued Order No. 720, requiring interstate pipelines to report no notice service on a point basis, the Commission stated that the requirement would not be unduly burdensome because “[a]n interstate natural gas pipeline should already have information on the no-notice service it provides.”  However, for each pipeline,… Read More

Standards of Conduct INGAA Request for Clarification and/or Rehearing 11-17-08

The Interstate Natural Gas Association of America (INGAA) appreciates the Commission’s Final Rule in this proceeding, Order No. 717, Standards of Conduct for Transmission Providers, 125 FERC ¶ 61,024 (October 16, 2008). As the Commission intended, the standards governing the relationship between interstate pipelines and their affiliated marketers are clearer and… Read More

INGAA Comments to the U.S. Environmental Protection Agency Advance Notice of Proposed Rulemaking (ANPR) regulating greenhouse gases under the Clean Air Act (CAA)

On July 30, 2008, the EPA issued an Advance Notice of Proposed Rulemaking (ANPR) requesting public comment on whether and how the agency should regulate emissions of greenhouse gases (GHG) using its authority under the Clean Air Act (CAA).  The ANPR is EPA’s initial response to the U.S. Supreme… Read More

Alternative Transportation Fuels: Natural Gas Implications

The INGAA Foundation, Inc. retained BBI International (BBI) to analyze the natural gas implications for future alternative fuels plants. This analysis looked at current and future biofuels plants and quantities and estimated thermal energy loads. Increased crop production to supply biofuels plants and the resulting increases in fertilizer requirements was reviewed. Read More

Control Room Management INGAA Comments

On November 12, INGAA filed comments on PHMSA’s notice of proposed rulemaking proposing an extension of regulations that would govern control room management for natural gas transmission pipelines and hazardous liquid pipelines.  The proposed regulations cover such topics as SCADA systems, alarms, controller fatigue, shift changes, training and executive verification… Read More

Unconventional Natural Gas : Availability

This report forecasts that North American unconventional natural gas recoverable reserves from tight gas, coalbed methane, and shale gas formations exceed 900 trillion cubic feet (Tcf).  The report states that overall recoverable natural gas resources in the U.S. and Canada exceed 2,330 Tcf.  Current annual U.S. and Canadian consumption of… Read More

Interagency Cooperation Under the Endangered Species Act INGAA Letter 11-3-08

The Interstate Natural Gas Association of America supports the Draft Environmental Assessment and shares the Services’ conclusion that the proposed amendments are wholly procedural, not substantive, and adopting these regulations would not cause any environmental effects warranting preparation of an environmental impact statement. Read More

Islander East No. 08-367 Supreme Court Brief Amici Curiae 10-23-08

Amici Curiae of INGAA, NGSA, AGA and IPAA in support of Petitioner Islander East Pipeline Company. In PUD No. 1 of Jefferson County v. Washington Dep’t of Ecology, 511 U. S. 700, 722 (1994), the Court reserved the question whether a state water quality certification under section 401 of the Clean Water… Read More

INGAA Comments Endangered Species Act 10-10-08

  The Interstate Natural Gas Association of America (INGAA) submits comments in response to the Proposed Revisions to the Endangered Species Act Section 7 Consultation Regulations, 73 Fed. Reg 47868 (August 15, 2008) by the U.S. Fish and Wildlife Service and NOAA’s National Marine Fisheries Service (collectively, Services).  INGAA… Read More

Foundation Studies

The Foundation’s primary activity is to sponsor research aimed at promoting natural gas use and safe, efficient pipeline construction and operation. These projects focus on key industry issues such as environmental impacts of energy use, improved pipeline construction practices, pipeline safety procedures, new technologies and market opportunities for natural gas. Read More

INGAA Voices Opposition to H.R. 6720

WASHINGTON – According to a letter issued by the Interstate Natural Gas Association of America (INGAA), H.R. 6720 (The Natural Gas Strategy Act), if enacted, would stifle investment in natural gas infrastructure at a critical time for the expansion of the nation’s energy transportation network.  INGAA released the following statement… Read More

INGAA opposition to H.R. 6720

According to the Interstate Natural Gas Association of America (INGAA), H.R. 6720 (The Natural Gas Strategy Act), if enacted, would stifle investment in natural gas infrastructure at a critical time for the expansion of the nation’s energy transportation network.   INGAA released the following statement by its president, Donald F. Santa,… Read More

State Tax Discrimination Supreme Court Brief Amici Curiae of INGAA 7-14-08

  On July 14, 2008, INGAA and the Council on State Taxation sumitted a brief Amici Curiae in Support of Petitioner, Columbia Gas Transmission Corporation in Columbia Gas Transmission Corporation v. Richard A. Levin, Tax Commissioner of Ohio, No. 07-1554.  The question presented in the case is whether an Ohio tax that… Read More

Stormwater Permitting INGAA�s 9th Cir. Amicus Curiae Letter 7-31-08

INGAA moves for leave to file an amicus curiae letter supporting the Environmental Protection Agency’s “Petition for Rehearing, With a Suggestion for Rehearing En Banc,” filed July 21, 2008.  In this case, a majority of the Panel in NRDC v. EPA, 526 F.3d 591 (2008), vacated… Read More

INGAA Comments – Combined Engine Rule – June 12

Comments on the U.S. EPA’s proposed rule Standards of Performance (New Source Performance Standards (NSPS)) for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants (NESHAP) for Reciprocating Internal Combustion Engines. The spark ignition internal combustion engine NSPS is proposed as 40 CFR Part 60,… Read More

Environmental Groups Threaten To Sue EPA for Failing to Update Air Rules

On July 2, 2008 a coalition of environmental groups sent a letter to the U.S. EPA (“agency”) indicating their intent to sue within 60 days over the agency’s failure to review and update three sets of air pollution regulations for oil and gas operations, including transmission and distribution. The fundamental issue… Read More

Fire Prevention and Control in Compressor Buildings

Solomon Associates (Solomon) is pleased to submit the Fire Prevention and Control Survey for the results obtained from a survey designed to gather information on the fire prevention and control practices of Interstate Natural Gas Association of America (INGAA) membership. Some insurance industry loss control inspectors are recommending or requiring installation… Read More

Natural Gas Transmission Communications: An Approach & Methodology For Relaying Key Messages Regarding the Interstate Natural Gas Pipeline Industry

This document (referred to hereafter as "the Plan") provides a framework of messages and opportunities that will assist INGAA, INGAA Foundation members and operators in the interstate natural gas transmission business to better communicate with a variety of key constituencies. The Plan is designed as a comprehensive reference piece… Read More

Cross Border Harmonization Phase 1

Canadian natural gas supplies over 15% of United States needs through an interconnected pipeline system with 18 border points. The robust and relatively seamless North American market for natural gas that has developed around this pipeline network has been made possible by complementary energy and regulatory policies in both countries. Read More

Discussion of Effects of Long-term Gas Commodity & Transportation Contracts on the Development of Natural Gas Infrastructure

This paper presents a discussion of contracts for natural gas commodity, transportation and storage services signed by large natural gas consumers and local distribution companies. The issues addressed here can be summarized by a series of questions:  Has the move away from long-term contracts in the U.S. gas industry increased… Read More