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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

As a result of discussions among the Interstate Natural Gas Association of America (INGAA), the American Gas Association (AGA) and our respective member companies about how to incorporate a proposed Natural Gas Council “Plus” technical framework on hydrocarbon liquid dropout and interchangeability specifications, INGAA and AGA have reached agreement… Read More

Pursuant to the notice of proposed rulemaking (NOPR) issued by the Federal Energy Regulatory Commission (FERC or Commission) on December 22, 2005,1 the Interstate Natural Gas Association of America (INGAA) submits the following supplemental reply comments in the above captioned proceeding. These supplemental reply comments respond to several points raised… Read More

All of INGAA’s members agree that the Commission’s eTariff proposal cannot be implemented in its present state of development. Pipeline comments will set out the defects. Many of INGAA’s members have serious concerns whether the eTariff proposal is salvageable. In any event, by whatever means the Commission decides to proceed… Read More

INGAA requests that the Commission, in its final rule, not require pipelines to accept surety bonds as an acceptable form of collateral.  INGAA further requests that the Commission, in its final rule, include all transportation charges, including reservation, usage or volumetric charges, and surcharges in the computation of collateral for… Read More

December 8, 2005, the Commission issued Order No. 667,1 in which it amended its regulations to implement the repeal of the Public Utility Holding Company Act of 1935 and the enactment of the Public Utility Holding Company Act of 2005. On April 24, 2006, the Commission issued Order No. Read More

Pursuant to Section 19(a) of the Natural Gas Act (“NGA”), 15 U.S.C. § 717r(a), and Rule 713 of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rules of Practice and Procedure, 18 C.F.R. § 385.713 (2003), the Interstate Natural Gas Association of America (“INGAA”) hereby submits its request for… Read More

Pursuant to the April 9, 2003 Notice of Proposed Rulemaking entitled Amendments to Conform Regulations to Order No. 630 (“Amendment NOPR”),1 the Interstate Natural Gas Association of America (“INGAA”) submits the following comments.INGAA supports the majority of the proposed amendments to the provisions of Part 157 of the Commission’s… Read More

To ensure that necessary natural gas transportation infrastructure is constructed, that natural gas transportation costs to consumers remain fair and reasonable, and that tribes are paid reasonable compensation for rights-of-way across their land, there must be an objective, consistent, transparent, and uniform standard for valuing these rights-of-way. While negotiations… Read More

FERC has failed to justify an extension of its Standards of Conduct to the non-marketing affiliates of interstate natural gas pipelines. The facts found by the Commission – the convergence of gas and electric markets, and the existence of trading affiliates and asset managers – do not support the… Read More