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The Associations, on behalf of their respective members, submit a Motion to extend the period for filing initial comments for an additional 15 days until March 30, 2007, and to extend the period for filing reply comments for an additional 10 days [...] Read More
INGAA submitted comments to the Bureau of Indian Affairs, urging that the US Department of Energy and US Department of the Interior (Departments) Draft Report to Congress required by section 1813 of the Energy Policy Act of 2005 continues to [...] Read More
INGAA requests clarification or, in the alternative, rehearing of the FERC’s (Commission) Interim Rule issued on January 9, 2007. The Interim Rule represents the Commission’s interim response to the decision of the United States Court of [...] Read More
INGAA filed an intervener’s reply brief in the HIOS/Petal litigation in the Court of Appeals for the DC Circuit. INGAA argues that FERC’s new rate of return policy, by basing pipeline returns on the returns earned by lower-risk LDCs, disregards [...] Read More
INGAA argues that FERC departed from precedent in permitting use of lower-risk LDCs in the proxy group for setting Petitioners’ rates, and arbitrarily foreclosed use of gas pipeline MLPs as proxies for determining a gas pipeline’s rate of [...] Read More
While INGAA recognizes that the Commission has made efforts to meet certain of the objections raised by the industry in comments on the Commission’s Notice of Proposed Rulemaking (“NOPR”) in this matter, the Final Rule adopted by the [...] Read More
Chairman Joseph T. Kelliher Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Docket No. EM06-5-000 Dear Chairman Kelliher: On November 22, 2005, I wrote to express the appreciation of the members of the [...] Read More
Standards for Business Practices for Interstate Natural Gas Pipelines and Standards for Business Practices for PubliPursuant to the Notice of Proposed Rulemaking issued October 25, 2006, INGAA submits the following comments on the Commission’s [...] Read More
Pursuant to the Commission's orders of October 20 and November 30, 2005, INGAA submits the following comments in reply to several of the comments filed in this proceeding on November 22, [...] Read More
Pursuant to Rules 212 and 2008 of the Federal Energy Regulatory Commission’s (Commission) Rules of Practice and Procedure, 18 C.F.R §§ 385.212 and 385.2008 (2001), the Association of Oil Pipe Lines (AOPL), Interstate Natural Gas [...] Read More
INGAA respectfully requests that the Commission grant this motion to extend the deadline for filing reply comments in this proceeding to December 9, [...] Read More
INGAA offers these comments in response to FERC's Request For Comments (“Request”), issued December 2, 2004, in Docket No. PL05-5-000. INGAA is a national, non-profit trade association that represents virtually all of the major interstate [...] Read More
The importance of sufficient pipeline infrastructure has been recognized frequently by the Commission and the industry. Many difficulties in maintaining this sufficiency have been encountered in recent years as a result of factors beyond the [...] Read More
INGAA suggests that there may be good cause for an audited company to move off of the shortened procedure track to trial-type procedures. INGAA requests that the Commission modify its proposed § 158.3 to provide that “upon a good cause showing by [...] Read More
As a matter of law, companies that perform only a gathering function, whether they are independent or affiliated with an interstate pipeline, are not natural gas companies because they neither transport natural gas in interstate commerce nor sell [...] Read More
The Commission must apply its expertise and exercise discretion in applying securities and commodities law precedent to the industries it regulates. The Commission should explicitly adopt the elements and limitations applicable to the SEC’s [...] Read More
INGAA requests that the Commission determine that INGAA’s letter does not constitute a prohibited off-the-record-communication in the circumstances. INGAA does not object to placing its November 2 letter in the non-decisional file in the above [...] Read More
Studies by the INGAA Foundation as well as the National Petroleum Council (“NPC”) confirm the need for very substantial new storage (up to 700Bcf) over the next two decades, at a cost in the range of $4 billion to $6 billion. See infra at 4. The [...] Read More
Pursuant to the Notice of Proposed Rulemaking issued September 21, 2006, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the Commission’s proposals to amend its regulations pertaining to critical [...] Read More
Pursuant to Rule 713(c)(1) and (2), the following is a specification of rehearing errors, along with the issues and law on which INGAA relies in this rehearing request: A. Noise Measurement. Whether the Commission erred in amending its regulations [...] Read More