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Pursuant to the Notice Soliciting Public Comment issued March 3, 2005, in these dockets, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the effectiveness of the Commission’s regulations for gaining access to critical energy infrastructure information (“CEII”). INGAA represents the interstate and interprovincial natural… Read More

In the NOPR, the Commission appropriately has recognized the importance of creditworthiness commitments in relation to the financing of new construction. Such commitments, however, are also critically important for new service agreements over existing pipeline capacity. This is especially true for new long-term agreements on existing capacity. Pipelines should… Read More

Pursuant to the Notice Seeking Comments issued March 2, 2005, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the two reports filed in this docket by the NGC+ Interchangeability Working Group and the Liquid Hydrocarbon Task Group: White Paper on Liquid Hydrocarbon Drop Out in… Read More

Pursuant to the Commission’s notice of proposed rulemaking (“NOPR”) issued on December 22, 2005, 113 FERC ¶ 61,306, the Interstate Natural Gas Association of America (“INGAA”) submits the following supplemental comments in this proceeding regarding market-based storage rates.As indicated in its comments filed February 27, INGAA represents the interstate… Read More

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.212 (2004), the Interstate Natural Gas Association of America (“INGAA”) hereby moves for leave to file reply comments to certain parties and hereby submits those reply comments. Read More

The Interstate Natural Gas Association of America (INGAA) is filing this motion pursuant to the Federal Energy Regulatory Commission (FERC or the Commission)’s Rule 212, 18 C.F.R. § 385.212. INGAA respectfully requests that the Commission: (1) grant an extension of time, from April 25, 2005 until April 18, 2007,… Read More

INGAA shares Commissioner Brownell’s concern that the Commission, through its broad ranging Notice in this case, is “creating market uncertainty with the specter of regulatory intervention, on a generic basis, in a discounting program that works well, promotes competition, provides regulatory safeguards and ultimately benefits gas consumers.” Concurrence at… Read More

It is widely recognized that the demand for additional natural gas storage capacity is increasing. Enactment of section 312 of the Energy Policy Act of 2005 (“EPAct”), 15 U.S.C. § 717c(f), permitting the Commission to approve storage projects at market-based rates even without a no-market-power showing, clearly demonstrates Congressional… Read More

INGAA’s filing of a “Petition for Clarification” with FERC while its petition for review was pending in this Court does not render the petition for review premature under this Court’s holdings in either Tennessee Gas Pipeline Co. v. FERC, 9 F.3d 980, 981 (D.C. Cir. 1993) or BellSouth v. FCC,… Read More

INGAA supports the Commission’s adoption of the standards proposed in the NOPR. INGAA requests, however, that the Commission grant a 90 day extension of the effective date for implementation of the standards. Read More

To INGAA’s knowledge, there is no current widespread Mobile-Sierra problem regarding the standard of review in the natural gas industry. INGAA has some concern, therefore, that the Commission’s proposal may, contrary to its goal, create contractual uncertainty where none exists. Nevertheless, if the Commission elects to proceed… Read More

Pursuant to section 15(d) of the Federal Rules of Appellate Procedure, and Circuit Rule 15(b), the Interstate Natural Gas Association of America (“INGAA”) moves to intervene in the following proceedings: Illinois Municipal Gas Agency v. FERCNorthern Municipal Distributors Group v. FERC… Read More

The Office of Pipeline Safety, Research and Special Programs Administration of the Department of Transportation (“OPS”) issued regulations (68 Fed. Reg. 69778)(“Final Rule”) in December 2003 to implement the Pipeline Safety Improvement Act of 2002 (“Pipeline Safety Act”). The OPS regulations established new integrity management requirements for natural gas… Read More

INGAA supports the Commission’s proposed adoption of the Version 1.6 Standards developed by the WGQ of NAESB. However, INGAA requests that the Commission modify the implementation timeline so that pipelines would implement the Version 1.6 Standards on the first of the month following 90 days after issuance of a final… Read More

The Commission is proposing to repeal its code of conduct regulations for interstate natural gas pipelines that hold blanket certificates for unbundled gas sales services (18 CFR § 284.288(2005)), and for persons that hold blanket marketing certificates for making gas sales for resale at negotiated rates in interstate commerce (18… Read More

In January 1999, the INGAA Foundation’s study, Pipeline and Storage Infrastructure Requirements for a 30 Tcf U.S. Gas Market, outlined the promise and the challenges of an unprecedented 30 trillion cubic foot natural gas market in the U.S. by 2010 that would be driven by significant growth in the… Read More

Increased reliance on natural gas will create many opportunities, but many challenges as well. The main challenge is that expansion of the natural gas market will result in increased emissions of methane (CH4), a potent greenhouse gas. The level of increased emissions is a function of the industry… Read More

The Natural Gas Act authorizes the construction and operation of interstate natural gas pipelines, with regulatory oversight by the Federal Energy Regulatory Commission (FERC). Since these activities are performed under the authority of the Federal government, National Environmental Policy Act (NEPA) reviews are required. Previous INGAA Foundation reports have forecast… Read More

Distributed generation has captured the interest of federal and state policymakers, excited potential developers and users and is becoming a part of the business strategies of utilities and other energy service providers. It has the potential to change the structure of electric power generation and distribution and redefine how electric… Read More

Over the past decade perhaps no external factor has influenced the energy industry more than technology.  From the wide spread use of automated real-time telemetry to using the Internet to conduct daily operations such as nominations, scheduling and invoicing, technology has drastically changed the way and the speed in… Read More