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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 ±«Óătv ("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 ±«Óătv (INGAA), I am writing to [...] Read More