Filings, Letters and Testimonies

INGAA submits comments and filings to various regulatory, congressional and administrative entities.  You can search by year, agency, and title using the search engine below.  Also, the most recent submissions are highlighted on the home page and appear in chronological order below the search engine.

Filing Topics
  • Congress 0
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  • Economics 10
  • Environment 21
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  • Safety 14
  • Security 1
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Filing
  • Filing 308
  • Letter 45
  • Testimony 19
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  • IASB 3
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  • USFWS 6
Date
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  • 1MB, PDF
    05/01/2018
    PHMSA
    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 ...
  • 190KB, PDF
    01/15/2010
    Voluntary Private Sector Accreditation and Certification Preparedness Program
    Office of Chief Counsel, Federal Emergency Management Agency
    Dan Regan
    On January 15, 2010 INGAA filed this letter regarding FEMA's Proposed PS-Prep Standards to docket number FEMA-2008-0017.
  • 59KB, PDF
    03/11/2016
    EPA
    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 ...
  • 279KB, PDF
    07/31/2017
    Post-Technical Conference Comments of the Interstate Natural Gas Association of America
    FERC
    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 ...
  • 47KB, PDF
    12/08/2004
    Federal Energy Regulatory Commission
    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
  • 144KB, PDF
    01/19/2005
    Accounting for Pipeline Assessment Costs
    Federal Energy Regulatory Commission
    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.
  • 36KB, PDF
    07/01/2004
    AGA et al. v. FERC, No. 04-1178
    US Court of Appeals for the District of Columbia Circuit
    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
  • 58KB, PDF
    02/17/2005
    AGA v. FERC
    US Court of Appeals for the District of Columbia Circuit
    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.
  • 156KB, PDF
    02/22/2005
    AGA v. FERC ROFR
    U.S. Court of Appeals for the D.C. Circuit
    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 ...
  • 256KB, PDF
    02/20/2018
    Supreme Court of the United States
    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 ...
  • 131KB, PDF
    07/01/2006
    ANR v. Louisiana Tax Commission
    Louisiana Court of Appeals, First Circuit
    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.
  • 275KB, PDF
    06/05/2018
    FERC
    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 ...
  • 21KB, PDF
    11/29/2005
    Procedures for Disposition of Contested Audit Matters
    Federal Energy Regulatory Commission
    INGAA
    Motion of INGAA to extend deadline for the filing of reply comments
  • 241KB, PDF
    01/03/2006
    Codes of Conduct for Unbundled Sales Service and for Persons Holding Blanket Marketing Certificates
    Federal Energy Regulatory Commission
    INGAA
    INGAA supports the proposal to repeal sections 284.288 and 284.403, with several qualifications.
  • 119KB, PDF
    08/25/2006
    Revisions to the Blanket Certificate Regulations and Clarification Regarding Rates
    Federal Energy Regulatory Commission
    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.
  • 85KB, PDF
    10/20/2006
    Revisions to the Blanket Certificate Regulations and Clarification Regarding Rates
    Federal Energy Regulatory Commission
    INGAA
    A specification of rehearing errors, along with the issues and law on which INGAA relies in this rehearing request: