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Pursuant to the Notice Seeking Comments issued March 2, 2005, the Interstate Natural Gas Association of America (“INGAA”) submits the following comments on the two reports filed in this docket by the NGC+ Interchangeability Working Group [...] Read More

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 [...] Read More

Pursuant to Rule 212 of the Rules of Practice and Procedure of the Federal Energy Regulatory Commission (“FERC” or “Commission”), 18 C.F.R. § 385.212 (2004), the Interstate Natural Gas Association of America (“INGAA”) hereby moves for [...] Read More

The Interstate Natural Gas Association of America (INGAA) is filing this motion pursuant to the Federal Energy Regulatory Commission (FERC or the Commission)’s Rule 212, 18 C.F.R. § 385.212. INGAA respectfully requests that the Commission: (1) [...] Read More

INGAA shares Commissioner Brownell’s concern that the Commission, through its broad ranging Notice in this case, is “creating market uncertainty with the specter of regulatory intervention, on a generic basis, in a discounting program that works [...] Read More

It is widely recognized that the demand for additional natural gas storage capacity is increasing. Enactment of section 312 of the Energy Policy Act of 2005 (“EPAct”), 15 U.S.C. § 717c(f), permitting the Commission to approve storage projects [...] Read More

INGAA’s filing of a “Petition for Clarification” with FERC while its petition for review was pending in this Court does not render the petition for review premature under this Court’s holdings in either Tennessee Gas Pipeline [...] Read More

INGAA supports the Commission’s adoption of the standards proposed in the NOPR. INGAA requests, however, that the Commission grant a 90 day extension of the effective date for implementation of the [...] Read More

To INGAA's knowledge, there is no current widespread Mobile-Sierra problem regarding the standard of review in the natural gas industry. INGAA has some concern, therefore, that the Commission’s proposal may, contrary to its goal, create [...] Read More

Pursuant to section 15(d) of the Federal Rules of Appellate Procedure, and Circuit Rule 15(b), the Interstate Natural Gas Association of America ("INGAA") moves to intervene in the following proceedings: Illinois Municipal Gas Agency v. [...] Read More

The Office of Pipeline Safety, Research and Special Programs Administration of the Department of Transportation ("OPS") issued regulations (68 Fed. Reg. 69778)(“Final Rule”) in December 2003 to implement the Pipeline Safety Improvement Act of [...] Read More

INGAA supports the Commission’s proposed adoption of the Version 1.6 Standards developed by the WGQ of NAESB. However, INGAA requests that the Commission modify the implementation timeline so that pipelines would implement the Version 1.6 [...] Read More

The Commission is proposing to repeal its code of conduct regulations for interstate natural gas pipelines that hold blanket certificates for unbundled gas sales services (18 CFR § 284.288(2005)), and for persons that hold blanket marketing [...] Read More

Increased reliance on natural gas will create many opportunities, but many challenges as well. The main challenge is that expansion of the natural gas market will result in increased emissions of methane (CH4), a potent greenhouse gas. The level of [...] Read More

While INGAA recognizes that the Commission has made efforts to meet certain of the objections raised by the industry in comments on the Commission’s Notice of Proposed Rulemaking (“NOPR”) in this matter, the Final Rule adopted by the [...] Read More

INGAA filed an intervener’s reply brief in the HIOS/Petal litigation in the Court of Appeals for the DC Circuit. INGAA argues that FERC’s new rate of return policy, by basing pipeline returns on the returns earned by lower-risk LDCs, disregards [...] Read More

INGAA argues that FERC departed from precedent in permitting use of lower-risk LDCs in the proxy group for setting Petitioners’ rates, and arbitrarily foreclosed use of gas pipeline MLPs as proxies for determining a gas pipeline’s rate [...] Read More

May 2, 2007 The Honorable Jeff Bingaman Chairman Energy and Natural Resources Committee U.S. Senate Washington, DC 20510 Dear Mr. Chairman: On behalf of the members of the Interstate Natural Gas Association of America (INGAA), I am writing to [...] Read More