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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

Interstate Pipelines Commit to Enhanced Communication with Landowners

WASHINGTON— Phillip D. Wright, President of Williams Gas Pipeline and Chairman of the Interstate Natural Gas Association of America (INGAA) Board of Directors, announced today that the interstate natural gas pipeline industry has adopted a set of commitments to enhance communications with landowners in connection with the construction of new… Read More

Electronic Tariff Filings INGAA Supplemental NOPR COmments 5-29-08 RM01-5

 INGAA requests that the Commission: (1) not impose a definite implementation date at this time to allow time for software development and testing, and continue to provide a testing site after implementation; (2) provide alternate procedures or a waiver of regulations in the event of an electronic system failure; and… Read More

Pipeline Safety: Standards for Increasing Maximum Allowable Operating Pressure for Gas Transmission Pipelines

On May 19,  2008 INGAA submitted comments in response to a Notice of Proposed Rulemaking ("NOPR") issued by the Pipeline and Hazardous Materials Safety Administration ("PHMSA") to promulgate regulations that would establish eligibility standards enabling certain natural gas transmission pipelines to operate at an increased maximum allowable operating pressure (“MAOP”). INGAA… Read More

Pipeline Posting Requirement INGAA Comments 3-18-08 RM08-2

INGAA requests the Commission retract the NOPR’s proposed amendment of 18 C.F.R. § 284.13(d), and thereby refrain from requiring interstate pipelines to post daily actual flows. Should the Commission instead go forward with an actual flow reporting requirement, INGAA requests the Commission revise its proposed regulations to not require the installation… Read More

Standards of Conduct INGAA Appendix to Comments 5-12-08 RM07-1

The appendix, in particular, is designed to show the reader, using the Word program’s redline/strikeout feature, the difference between the regulatory text proposed by the Commission in it’s Notice for Proposed Rulemaking, and the changes to that text that INGAA is proposing in its comments. Please see Standards of Conduct… Read More

Standards of Conduct INGAA Comments 5-12-08 RM07-1

INGAA’s comments were generally supportive of FERC’s proposed new approach, which focuses on (1) “marketing” activities rather than the more expansive concept of “Energy Affiliate” activities, and (2) on the functions performed by individual employees, as opposed to a “corporate” separation approach that attempts to establish the primary business function… Read More

Proxy Group INGAA Post-technical Conference Supplemental Workpaper 3-12-08

Attached to the Interestate Natural Gas Association of America (“INGAA”)’s post-technical conference supplemental comments is an affidavit of its witness, Dr. Michael J. Vilbert, in response to the Reply Comments of the State of Alaska. Dr. Vilbert’s affidavit, Table 1, references a workpaper. … Read More

Proxy Group INGAA Post-technical Conference Supplemental Comments 3-12-08

At the January 23, 2008 technical conference, the Commission Staff stated its intent to seek Commission approval for a round of reply comments in addition to the round of initial comments scheduled by the Commission. On January 31, 2008, the Commission issued its Notice of Opportunity for Filing Reply Comments. On February… Read More

Proxy Group INGAA Post-Technical Conference Comments 2-11-08

These comments reinforce INGAA’s position that the Commission’s use of GDP for the long-term growth variable of the Discounted Cash Flow methodology produces reasonable results and should be retained. Read More