Comments on Pipeline Safety: Safety Of Gas Transmission Pipelines, MAOP Reconfirmation, Expansion Of Assessment Requirements And Other Related Amendments 1MB, PDF Date Sent 05/01/2018Recipient Agency PHMSASender AGA, API, APGA & INGAA The American Gas Association (AGA), American Petroleum Institute (API), American Public Gas Association (APGA) and Interstate Natural Gas Association of America (INGAA) (jointly “the Associations”) submit these comments for consideration by the Pipeline and Hazardous Materials Safety ... Read More
INGAA Letter Comment re FEMA's Proposed PS-Prep Standards 190KB, PDF Date Sent 01/15/2010Subject Voluntary Private Sector Accreditation and Certification Preparedness ProgramRecipient Agency Office of Chief Counsel, Federal Emergency Management AgencySender Dan Regan On January 15, 2010 INGAA filed this letter regarding FEMA's Proposed PS-Prep Standards to docket number FEMA-2008-0017. Read More
INGAA responds to EPA's request for information for the Natural Gas Transmission and Storage NESHAP (40 CFR, Part 63, Subpart HHH) 59KB, PDF Date Sent 03/11/2016Recipient Agency EPASender INGAA In November 2011, INGAA commented on proposed amendments. In response to final Subpart HHH amendments published in August 2012, INGAA submitted a request for reconsideration in September 2012. INGAA understands that EPA likely will amend Subpart HHH after evaluating new information received from ... Read More
Post-Technical Conference Comments of the Interstate Natural Gas Association of America 279KB, PDF Date Sent 07/31/2017Subject Post-Technical Conference Comments of the Interstate Natural Gas Association of AmericaRecipient Agency FERCSender INGAA Pursuant to the Federal Energy Regulatory Commission’s (“FERC” or “Commission”) “Notice of Technical Conference (“Notice”) and “Supplemental Notice of Technical Conference” (“Supplemental Notice”) on developments in ... Read More
5 Income Tax Allowance Extension Motion 47KB, PDF Date Sent 12/08/2004Recipient Agency Federal Energy Regulatory CommissionSender INGAA The Association of Oil Pipe Lines (AOPL), the Edison Electric Institute (EEI), and INGAA filing motion for an extension of time to respond to request for comment on Docket No. PF05-5 Read More
Accounting for Pipeline Assessment Costs Comments of the INGAA 1-19-05 144KB, PDF Date Sent 01/19/2005Subject Accounting for Pipeline Assessment CostsRecipient Agency Federal Energy Regulatory CommissionSender INGAA INGAA agrees that Commission guidance on the proper accounting treatment of these costs is appropriate, but disagrees with the Chief Accountant’s proposal to treat these activities as maintenance expenses. Read More
Additional Comments of The Interstate Natural Gas Association of America on the PHMSA Draft Integrity Verification Process 678KB, PDF Date Sent 10/07/2013Subject Additional Comments of The Interstate Natural Gas Association of America on the PHMSA Draft Integrity Verification ProcessRecipient Agency PHMSASender The Interstate Natural Gas Association of America Additional Comments of The Interstate Natural Gas Association of America on the PHMSA Draft Integrity Verification Process Read More
AGA et al. v. FERC INGAA Motion to Govern 10-08-04 22KB, PDF Date Sent 10/08/2004Subject AGA et al. v. FERC, No. 04-1178Recipient Agency U.S. Court of Appeals for the D.C. CircuitSender INGAA INGAA moves the Court to continue to hold cases in abeyance for 60 days. Read More
AGA et al. v. FERC INGAA Motion to Intervene 7-1-04 36KB, PDF Date Sent 07/01/2004Subject AGA et al. v. FERC, No. 04-1178Recipient Agency US Court of Appeals for the District of Columbia CircuitSender INGAA INGAA moves to intervene in AGA et al. v. FERC, US Court of Appeals for the District of Columbia Circuit, Docket No. 04-1178 Read More
AGA v. FERC INGAA Show Cause Petition 2-17-05 58KB, PDF Date Sent 02/17/2005Subject AGA v. FERCRecipient Agency US Court of Appeals for the District of Columbia CircuitSender INGAA Pursuant to the Court’s Order of January 18, 2005, Petitioner Interstate Natural Gas Association of America (“INGAA”) shows cause why its petition for review in consolidated No. 04-1318 should not be dismissed for lack of jurisdiction. Read More
AGA v. FERC ROFR Joint Brief of Intervenors INGAA and DEGT Pipelines in Support of Respondent 2-22-05 156KB, PDF Date Sent 02/22/2005Subject AGA v. FERC ROFRRecipient Agency U.S. Court of Appeals for the D.C. CircuitSender INGAA INGAA and the DEGT Pipelines, the Intervenors in Support of Respondent (hereinafter "Intervenors"), adopt the Commission’s statement of the ROFR issue: Whether the Commission reasonably concluded that no term-matching cap was necessary for the right of first refusal because existing regulatory ... Read More
Allowance for Funds Used During Construction INGAA Motion to Interevene and Request for Rehearing 9-28-09 76KB, PDF Date Sent 09/28/2009Subject AFUDCRecipient Agency FERCSender INGAA INGAA Motion to Intervene and Request for Rehearing in Southern Natural Gas Co. Read More
Amici Curiae in Support of Constitution Pipeline Company in Supreme Court Case Concerning Section 401 of the Clean Water Act 256KB, PDF Date Sent 02/20/2018Recipient Agency Supreme Court of the United StatesSender NAM, API, NGSA, AGA, AFPM, INGAA This case raises critical questions regarding the careful federal-State balance Congress struck in the process for approving interstate pipeline projects. Interstate pipelines offer significant benefits to the Nation. Their construction, operation and maintenance boost economic activity, and ... Read More
ANR v. Louisiana Tax Commission INGAA Amicus Brief 7-2006 131KB, PDF Date Sent 07/01/2006Subject ANR v. Louisiana Tax CommissionRecipient Agency Louisiana Court of Appeals, First CircuitSender INGAA INGAA's Amicus Brief on whether Louisiana violated the interstate pipelines’ right under the Due Process Clause to a “clear and certain remedy” for the payment of an unconstitutional tax when Louisiana refused to refund the tax unlawfully collected, and instead, in order to lessen or eliminate the refund, ordered a de novo re- valuation of taxpayers’ property by 52 local assessors. Read More
Answer to Notice of Inquiry on Accumulated Deferred Income Taxes 275KB, PDF Date Sent 06/05/2018Recipient Agency FERCSender INGAA INGAA responds to the argument made by commenters that the elimination of a tax allowance for MLPs and potentially other pass-through entities must result in the expeditious return of excess ADIT to customers of such pipelines. For the reasons stated in INGAA’s comments, ADIT issues ... Read More
Appendix A - Blade Report - Reliability Based Assessment of Pipeline Class Changes 858KB, PDF Date Sent 12/15/2020Subject Reliability Based Assessment of Pipeline Class Changes Underground gas transmission pipelines are classified according to the presence of human populations in their proximity. These classifications are governed by PHMSA regulation (49 Code of Federal Regulations (CFR) Section 192.5) and industry standards. Operations, maintenance and integrity ... Read More
Audit Matters INGAA Extension Motion 11-29-05 21KB, PDF Date Sent 11/29/2005Subject Procedures for Disposition of Contested Audit MattersRecipient Agency Federal Energy Regulatory CommissionSender INGAA Motion of INGAA to extend deadline for the filing of reply comments Read More
Audit Matters INGAA Reply Comments 12-9-05 44KB, PDF Date Sent 12/09/2005Subject Procedures for Disposition of Contested Audit MattersRecipient Agency Federal Energy Regulatory CommissionSender INGAA Reply comments Read More
Blanket Certificates Comments of INGAA 1-3-06 241KB, PDF Date Sent 01/03/2006Subject Codes of Conduct for Unbundled Sales Service and for Persons Holding Blanket Marketing CertificatesRecipient Agency Federal Energy Regulatory CommissionSender INGAA INGAA supports the proposal to repeal sections 284.288 and 284.403, with several qualifications. Read More
Blanket Certificates INGAA Comments 8-25-06 119KB, PDF Date Sent 08/25/2006Subject Revisions to the Blanket Certificate Regulations and Clarification Regarding RatesRecipient Agency Federal Energy Regulatory CommissionSender INGAA INGAA submits the following comments on the Commission's proposal to amend its blanket certification regulations (Part 157, subpart F), by expanding the scope and scale of activities that may be undertaken pursuant to blanket authority. Read More