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The Commission’s financial forms perform an important function by providing the Commission and the industry with a snapshot of the financial position of an interstate pipeline during the reporting period. As they are currently designed, preparation of the forms does not require pipelines to engage in projections or to… Read More
INGAA submitted a response to questions posed by the Commission, along with comments on the petition for rulemaking to remove the cap on released capacity filed by Pacific Gas and Electric Company (PG&E) and Southwest Gas Company in RM06-21, and the petition for clarification of the capacity regulations riled… Read More
INGAA comments are in response to FERC’s Notice of Proposed Rulemaking to establish new permanent affiliate regulations. INGAA requests that the Commission issue a Final Rule in this docket consistent with the following comments: 1.The Commission should permanently exclude non-marketing affiliates from the reach of the… Read More
Pursuant to the Commission’s “Notice of Inquiry” into the need for changes or revisions to its reporting requirements for financial forms issued February 15, 2007, submits comments principally directed at the Commission’s Form Nos. 2 and 2-A, “Annual Report for Major and Nonmajor Natural Gas Companies.” Those forms… Read More
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 until April 30, 2007 in the Commission’s… 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 misinterpret the nature of tribal sovereignty and tribal authority… 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 Appeals for the District of Columbia Circuit vacating Order No. 2004 series 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 the increased competition FERC has successfully fostered in the… 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 return. 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 Commission is too broad, and the new requirements are unnecessary to… 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 proposal to amend its open access regulations governing standards for business practices and electronic communications with… 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, 2005. 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 Association of America (INGAA), and Edison Electric Institute (EEI) (hereinafter referred to as Movants) hereby… 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, 2005. 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 natural gas transmission companies operating in the United States. The issues being considered by… 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 Commission’s control, such as the use by project opponents of statutes and post-certificate review… 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 the audited person, the Commission may permit a… 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 natural gas in interstate commerce for resale. See 15 U.S.C. §… 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 Enforcement of Rule 10b-5, and adopt procedures for obtaining advice and guidance with respect to… Read More