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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

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

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

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

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

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

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

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

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

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

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