Capacity Release INGAA Comments 1-25-08

On January 25, INGAA filed comments on the Commission’s notice of proposed rulemaking in which it proposed to lift the maximum rate cap on short-term capacity release transactions and relax the tying prohibition and bidding requirements to facilitate asset management agreements (AMAs).  LDCs and other major pipeline shippers employ AMAs to manage their capacity holdings efficiently.

INGAA agreed in general with FERC’s proposed reforms but, consistent with its initial position in response to FERC’s earlier comment solicitation, advocated that FERC release the cap on the entire short-term market (i.e., include short-term pipeline transportation and storage services).  With respect to AMAs, INGAA supported the proposal, but urged FERC to ensure that pipelines are not saddled with the responsibility for enforcing the specific AMA compliance requirements proposed by FERC.