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Pursuant to the Commission's orders of October 20 and November 30, 2005, INGAA submits the following comments in reply to several of the comments filed in this proceeding on November 22, [...] Read More
Pursuant to Rules 212 and 2008 of the Federal Energy Regulatory Commission’s (Commission) Rules of Practice and Procedure, 18 C.F.R §§ 385.212 and 385.2008 (2001), the Association of Oil Pipe Lines (AOPL), Interstate Natural Gas [...] Read More
INGAA respectfully requests that the Commission grant this motion to extend the deadline for filing reply comments in this proceeding to December 9, [...] Read More
INGAA offers these comments in response to FERC's Request For Comments (“Request”), issued December 2, 2004, in Docket No. PL05-5-000. INGAA is a national, non-profit trade association that represents virtually all of the major interstate [...] Read More
The importance of sufficient pipeline infrastructure has been recognized frequently by the Commission and the industry. Many difficulties in maintaining this sufficiency have been encountered in recent years as a result of factors beyond the [...] Read More
INGAA suggests that there may be good cause for an audited company to move off of the shortened procedure track to trial-type procedures. INGAA requests that the Commission modify its proposed § 158.3 to provide that “upon a good cause showing by [...] Read More
As a matter of law, companies that perform only a gathering function, whether they are independent or affiliated with an interstate pipeline, are not natural gas companies because they neither transport natural gas in interstate commerce nor sell [...] Read More
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