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The Interstate Natural Gas Association of America supports the Draft Environmental Assessment and shares the Services’ conclusion that the proposed amendments are wholly procedural, not substantive, and adopting these regulations would not [...] Read More
Amici Curiae of INGAA, NGSA, AGA and IPAA in support of Petitioner Islander East Pipeline Company. In PUD No. 1 of Jefferson County v. Washington Dep’t of Ecology, 511 U. S. 700, 722 (1994), the Court reserved the question whether a [...] Read More
The Interstate Natural Gas Association of America (INGAA) submits comments in response to the Proposed Revisions to the Endangered Species Act Section 7 Consultation Regulations, 73 Fed. Reg 47868 (August 15, 2008) by the U.S. Fish and [...] Read More
WASHINGTON – According to a letter issued by the Interstate Natural Gas Association of America (INGAA), H.R. 6720 (The Natural Gas Strategy Act), if enacted, would stifle investment in natural gas infrastructure at a critical time for the [...] Read More
According to the Interstate Natural Gas Association of America (INGAA), H.R. 6720 (The Natural Gas Strategy Act), if enacted, would stifle investment in natural gas infrastructure at a critical time for the expansion of the nation’s energy [...] Read More
On July 14, 2008, INGAA and the Council on State Taxation sumitted a brief Amici Curiae in Support of Petitioner, Columbia Gas Transmission Corporation in Columbia Gas Transmission Corporation v. Richard A. Levin, Tax Commissioner [...] Read More
INGAA moves for leave to file an amicus curiae letter supporting the Environmental Protection Agency’s “Petition for Rehearing, With a Suggestion for Rehearing En Banc,” filed July 21, 2008. In this case, a majority of the [...] Read More
Comments on the U.S. EPA’s proposed rule Standards of Performance (New Source Performance Standards (NSPS)) for Stationary Spark Ignition Internal Combustion Engines and National Emission Standards for Hazardous Air Pollutants (NESHAP) for [...] Read More
On July 2, 2008 a coalition of environmental groups sent a letter to the U.S. EPA (“agency”) indicating their intent to sue within 60 days over the agency's failure to review and update three sets of air pollution regulations for oil and [...] Read More
WASHINGTON— Phillip D. Wright, President of Williams Gas Pipeline and Chairman of the Interstate Natural Gas Association of America (INGAA) Board of Directors, announced today that the interstate natural gas pipeline industry has adopted a set [...] Read More
INGAA requests that the Commission: (1) not impose a definite implementation date at this time to allow time for software development and testing, and continue to provide a testing site after implementation; (2) provide alternate procedures or [...] Read More
On May 19, 2008 INGAA submitted comments in response to a Notice of Proposed Rulemaking ("NOPR") issued by the Pipeline and Hazardous Materials Safety Administration ("PHMSA") to promulgate regulations that would establish [...] Read More
INGAA requests the Commission retract the NOPR’s proposed amendment of 18 C.F.R. § 284.13(d), and thereby refrain from requiring interstate pipelines to post daily actual flows. Should the Commission instead go forward with an actual [...] Read More
The appendix, in particular, is designed to show the reader, using the Word program’s redline/strikeout feature, the difference between the regulatory text proposed by the Commission in it's Notice for Proposed Rulemaking, and the changes to [...] Read More
INGAA's comments were generally supportive of FERC's proposed new approach, which focuses on (1) “marketing” activities rather than the more expansive concept of “Energy Affiliate” activities, and (2) on the functions [...] Read More
Attached to the Interestate Natural Gas Association of America (“INGAA”)'s post-technical conference supplemental comments is an affidavit of its witness, Dr. Michael J. Vilbert, in response to the Reply Comments of the State of [...] Read More
At the January 23, 2008 technical conference, the Commission Staff stated its intent to seek Commission approval for a round of reply comments in addition to the round of initial comments scheduled by the Commission. On January 31, 2008, the [...] Read More
These comments reinforce INGAA's position that the Commission’s use of GDP for the long-term growth variable of the Discounted Cash Flow methodology produces reasonable results and should be [...] Read More
In response to the Commission’s “Notice of Technical Conference and Request for Additional Comments,”[1] issued on November 15, 2007, the Interstate Natural Gas Association of America (“INGAA”) hereby submits the [...] Read More
On January 25, INGAA filed comments on the Commission’s notice of proposed rulemaking in which it proposed to lift the maximum rate cap on short-term capacity release transactions and relax the tying prohibition and bidding requirements to [...] Read More