Underground Storage INGAA Supplemental Comments 3-21-06

Filed by
INGAA
Filed Date
03/21/2006
Recipients Agency
Federal Energy Regulatory Commission
Subject
Rate Regulation of Certain Underground Storage Facilities
Docket ID:
RM05-23, AD04-11
More On This
Rate Regulation of Certain Underground Storage Facilities
3.21.06 RM05-23 AD04-11 Underground Storage INGAA Supplemental Comments 116KB, PDF
03/21/2006
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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 regarding market-based storage rates.

As indicated in its comments filed February 27, INGAA represents the interstate natural gas pipeline industry and has an interest in this proceeding, inasmuch as many of its members own or operate competing natural gas storage and transportation facilities. INGAA recognizes that the Commission’s NOPR did not specifically provide for replies or supplemental comments. Nevertheless, in view of the focus of many comments that urge the Commission to adopt regulations that would restrict competition by excluding or handicapping pipeline-owned or affiliated storage, INGAA submits that the following brief comments are appropriate, and would aid the Commission in its deliberations. In order to put the economic considerations into a proper focus, INGAA is attaching an affidavit of an economist with extensive natural gas industry experience. See attached affidavit of John Neri, Ph.D.
LAST UPDATE
07/12/2007
Categories
FERC