Posted January 8, 2009

When it issued Order No. 720, requiring interstate pipelines to report no notice service on a point basis, the Commission stated that the requirement would not be unduly burdensome because “[a]n interstate natural gas pipeline should already have information on the no-notice service it provides.” However, for each pipeline, the information it has is a function of how it provides nooâ€notice service as well as its metering and measurement equipment. 73 Fed. Reg. at 73515. In a related context, the Commission also recognized that some volumes are simply too inconsequential to warrant the cost and administrative burden necessary to comply with this rule. 73 Fed. Reg. at 73509-12.

Consistent with these provisions of Order No. 720, and in light of the facts, authorities and arguments presented above, INGAA requests the Commission issue an order (1) clarifying the Final Rule to address the the following issues:

(a) The Commission should clarify that an interstate pipeline satisfies the"no-notice" posting requirement if it provides volume information at the level of detail and aggregation corresponding to how that pipeline provides "no-notice" transportation;

(b) The Commission should clarify that an interstate pipeline satisfies the"no-notice" posting requirement by providing whatever volume information is available throuhg metering and measurement equipment in place at the time the information is posted; and

(c) The Commission should clarify that an interstate pipeline satisfies the"no-notice" posting requirement without having to post delivery points with an average annual delivery rate of less than 2,500 Mcf per day.

In addition, INGAA requests the Commission issue an order, as necessary and appropriate, (2) granting rehearing to amend to the regulatory text promulgated through Order No. 720.

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