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Audit Matters INGAA Comments 11-22-05

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

Gathering INGAA Comments 11-22-05

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

Market Manipulation INGAA Comments 11-17-05

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

INGAA Answer to BP Ex Parte 11-17-04

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 dockets — INGAA takes no position on the specific merits of those proceedings — and… Read More

Storage-Infrastructure INGAA Comments 11-15-04

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 development of additional… Read More

CEII INGAA Comments 11-02-06

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 energy infrastructure information (“CEII”). INGAA represents the interstate and interprovincial natural gas pipeline industry operating… Read More

Blanket Certificates INGAA Request for Rehearing 10-20-06

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 at 18 CFR § 157.206(b)(5)(i) to… Read More

AGA et al. v. FERC INGAA Motion to Govern 10-08-04

September 7, 2004, the Court granted the joint motion of Petitioners American Gas Association, et al, to hold these consolidated cases in abeyance, and directed the parties to file motions to govern future proceedings on October 8, 2004. The Interstate Natural Gas Association of America (“INGAA”), Petitioner in No. 04-1318,… Read More

Blanket Certificates Joint NGSA INGAA Letter to Kelliher 9-19-06

Last November the Interstate Natural Gas Association of America (INGAA) and the Natural Gas Supply Association (NGSA) jointly petitioned the Commission to initiate a rulemaking to improve blanket certificate procedures. The Commission followed up on that joint recommendation expeditiously, issuing its Notice of Proposed Rulemaking (NOPR) in June in… Read More

Storage Reporting INGAA Comments 9-10-04

Without storage data from the non-jurisdictional intrastate, LDC, and independent storage operators, which control almost one half the national inventory, there would be a substantial defect in the data base. In addition, daily storage data, unlike longer-term data, is vulnerable to significant and unrepresentative day-to-day fluctuations. Therefore, from the… Read More

Section 1813 Native American Rights-of-Way INGAA Comments 9-3-06

The Interstate Natural Gas Association of America (INGAA) submits the following comments on the U.S. Department of Energy and U.S. Department of the Interior Draft Report to Congress required by section 1813 of the Energy Policy Act of 2005. INGAA is a national, non-profit trade association that represents the… Read More

Standards of Conduct INGAA Petition for Clarification 9-1-04

Pursuant to Rule 207(a)(5) of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rule of Practice and Procedure, 18 CFR § 385.207(a)(5), the Interstate Natural Gas Association of America (“INGAA”) petitions for clarification in the above-referenced proceeding. Read More

Williston Discount INGAA Reply Comments 8-30-04

In general, the comments submitted confirm INGAA’s view that the CIG/Granite State policy is based on an unsupported presumption that shippers with discounted firm primary capacity are similarly situated with any shipper that has previously obtained a discount for either firm or interruptible transportation at any other point on… Read More

Blanket Certificates INGAA Comments 8-25-06

INGAA and NGSA petitioned the Commission in November 2005 to expand its blanket certificate program. While Petitioners found little room for improvement in the Commission’s processing of certificate applications, we urged a few changes that would accelerate the process, with the ultimate goal of facilitating the efficient construction of… Read More

CZMA INGAA Comments on NOAA Proposal 8-25-03

Pursuant to the proposed rule issued in the referenced proceeding on June 11, 2003, 1 the Interstate Natural Gas Association of America (INGAA) submits the following comments on the National Oceanic and Atmospheric Administration’s (NOAA) proposal to revise the Federal Consistency regulations promulgated under the Coastal Zone Management Act… Read More

Williston Discount INGAA Motion to Intervene and Comments 8-9-04

In response to the decision of the United States Court of Appeals for the D.C. Circuit in Williston Interstate Pipeline Co. v. FERC, 358 F.3d 45 (2004), the Commission asked interested persons for their views as to whether it should (1) adhere to the policy on pipeline discounting announced… Read More

ANR v. Louisiana Tax Commission INGAA Amicus Brief 7-2006

Louisiana’s attempt to circumvent the remedial obligation imposed by the due process clause presents a significant question that warrants review by this court: The decision conflicts with decisions of this court and other state appellate courts on a recurring question of substan-tial importance – the contours of… Read More

Coordinating Federal Authorization INGAA Comments 7-31-06

Pursuant to the Notice of Proposed Rulemaking issued by the Federal Energy Regulatory Commission in the captioned proceeding on May 18, 2006, INGAA submits the following comments addressing the Commission’s proposed regulations for coordinating the processing of Federal authorizations for natural gas infrastructure projects subject to sections 3 and… Read More

Reporting Regulations INGAA Comments 7-25-05

INGAA supports the Commission’s basic proposal to permit electronic filing of reports under §§ 260.9 and 284.270, and to make provision for CEII treatment of the material, and recommends clarification on several points. Read More

Reporting Requirements INGAA Comments 7-9-06

In the short term, the Commission should tailor its proposed damage reporting proposal, as described above, to avoid the reporting of information that is not relevant to the Commission’s purpose of obtaining an accurate picture of the natural gas infrastructure in the event of disasters. For the long term, the… Read More