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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

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