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 natural gas pipeline industry and has an interest in this proceeding, inasmuch as many of its members own or operate competing natural gas storage and transportation facilities. INGAA recognizes that the Commission’s NOPR did not specifically provide for replies or supplemental comments. Nevertheless, in view of the focus of many comments that urge the Commission to adopt regulations that would restrict competition by excluding or handicapping pipeline-owned or affiliated storage, INGAA submits that the following brief comments are appropriate, and would aid the Commission in its deliberations. In order to put the economic considerations into a proper focus, INGAA is attaching an affidavit of an economist with extensive natural gas industry experience. See attached affidavit of John Neri, Ph.D.Related
Natural Gas & Power Industries’ Reliability Alliance:
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
Exploring Real-Life Challenges with Ensuring Natural Gas Availability for Power and Joint Industry Suggested Mitigation Strategies INGAA Comments on FERC NOPR on Cybersecurity Incentives for Electric Utilities INGAA Incident Reporting Comments INGAA API Petition for Consideration of Gas Transmission Final Rule
