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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

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

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

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

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

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

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

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

Pursuant to Rule 15(d) of the Federal Rules of Appellate Procedure, the Interstate Natural Gas Association of America (“INGAA”) moves to intervene in these consolidated cases.  In support, INGAA states as follows: 1. Petitioners seek review of the following orders of the Federal Energy Regulatory Commission (FERC)… Read More

In its orders requiring pipelines to expense their Pipeline Safety Act costs, the Commission ignored the obligations imposed by the OPS IM Regulations, departed from its own precedent, failed to respond to substantial arguments of INGAA, and otherwise failed to provide a reasoned explanation for its decision. Read More

Pursuant to Section 15(d) of the Federal Rules of Appellate Procedure, the Interstate Natural Gas Association of America (“INGAA”) moves to intervene in Petal v. FERC, US Court of Appeals for the District of Columbia Circuit No. 04-1166. Read More

A. Implementation of the NGC+ White Papers Nationwide standards for hydrocarbon drop out and interchangeability are a laudable goal. The challenge in articulating and implementing a policy to achieve this goal is that there is variability in the composition of the supply of gas, variability in pipeline… Read More