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The Commission must apply its expertise and exercise discretion in applying securities and commodities law precedent to the industries it regulates. The Commission should explicitly adopt the elements and limitations applicable to the SEC’s [...] Read More

INGAA requests that the Commission determine that INGAA’s letter does not constitute a prohibited off-the-record-communication in the circumstances. INGAA does not object to placing its November 2 letter in the non-decisional file in the above [...] Read More

Studies by the INGAA Foundation as well as the National Petroleum Council (“NPC”) confirm the need for very substantial new storage (up to 700Bcf) over the next two decades, at a cost in the range of $4 billion to $6 billion. See infra at 4. The [...] Read More

Pursuant to the Notice of Proposed Rulemaking issued September 21, 2006, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the Commission’s proposals to amend its regulations pertaining to critical [...] Read More

Pursuant to Rule 713(c)(1) and (2), the following is a specification of rehearing errors, along with the issues and law on which INGAA relies in this rehearing request: A. Noise Measurement. Whether the Commission erred in amending its regulations [...] Read More

September 7, 2004, the Court granted the joint motion of Petitioners American Gas Association, et al, to hold these consolidated cases in abeyance, and directed the parties to file motions to govern future proceedings on October 8, 2004. The [...] Read More

Last November the Interstate Natural Gas Association of America (INGAA) and the Natural Gas Supply Association (NGSA) jointly petitioned the Commission to initiate a rulemaking to improve blanket certificate procedures. The Commission followed up on [...] Read More

Without storage data from the non-jurisdictional intrastate, LDC, and independent storage operators, which control almost one half the national inventory, there would be a substantial defect in the data base. In addition, daily storage data, unlike [...] Read More

The Interstate Natural Gas Association of America (INGAA) submits the following comments on the U.S. Department of Energy and U.S. Department of the Interior Draft Report to Congress required by section 1813 of the Energy Policy Act of 2005. INGAA [...] Read More

Pursuant to Rule 207(a)(5) of the Federal Energy Regulatory Commission’s (“Commission” or “FERC”) Rule of Practice and Procedure, 18 CFR § 385.207(a)(5), the Interstate Natural Gas Association of America (“INGAA”) petitions for [...] Read More

In general, the comments submitted confirm INGAA’s view that the CIG/Granite State policy is based on an unsupported presumption that shippers with discounted firm primary capacity are similarly situated with any shipper that has previously [...] Read More

INGAA and NGSA petitioned the Commission in November 2005 to expand its blanket certificate program. While Petitioners found little room for improvement in the Commission’s processing of certificate applications, we urged a few changes that would [...] Read More

Pursuant to the proposed rule issued in the referenced proceeding on June 11, 2003, 1 the Interstate Natural Gas Association of America (INGAA) submits the following comments on the National Oceanic and Atmospheric Administration’s (NOAA) proposal [...] Read More

In response to the decision of the United States Court of Appeals for the D.C. Circuit in Williston Interstate Pipeline Co. v. FERC, 358 F.3d 45 (2004), the Commission asked interested persons for their views as to whether it should (1) adhere to [...] Read More

Louisiana’s attempt to circumvent the remedial obligation imposed by the due process clause presents a significant question that warrants review by this court: The decision conflicts with decisions of this court and other state appellate courts on [...] Read More

Pursuant to the Notice of Proposed Rulemaking issued by the Federal Energy Regulatory Commission in the captioned proceeding on May 18, 2006, INGAA submits the following comments addressing the Commission’s proposed regulations for coordinating [...] Read More

INGAA supports the Commission’s basic proposal to permit electronic filing of reports under §§ 260.9 and 284.270, and to make provision for CEII treatment of the material, and recommends clarification on several [...] Read More

In the short term, the Commission should tailor its proposed damage reporting proposal, as described above, to avoid the reporting of information that is not relevant to the Commission's purpose of obtaining an accurate picture of the natural gas [...] Read More

Pursuant to Rule 15(d) of the Federal Rules of Appellate Procedure, the Interstate Natural Gas Association of America (“INGAA”) moves to intervene in these consolidated cases.  In support, INGAA states as follows: 1. Petitioners seek review [...] Read More

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 [...] Read More