Filings, Letters and Testimonies

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 ...

On January 15, 2010 INGAA filed this letter regarding FEMA's Proposed PS-Prep Standards to docket number FEMA-2008-0017.

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 ...

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 ...

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

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.

Additional Comments of The Interstate Natural Gas Association of America on the PHMSA Draft Integrity Verification Process

INGAA moves the Court to continue to hold cases in abeyance for 60 days.

INGAA moves to intervene in AGA et al. v. FERC, US Court of Appeals for the District of Columbia Circuit, Docket No. 04-1178

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.

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 ...

INGAA Motion to Intervene and Request for Rehearing in Southern Natural Gas Co.

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 ...

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.

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 ...

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 ...

Motion of INGAA to extend deadline for the filing of reply comments

Reply comments

INGAA supports the proposal to repeal sections 284.288 and 284.403, with several qualifications.

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.