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The Implications of PURPA Reform for the Natural Gas Industry

The Public Utility Regulatory Policies Act of 1978 ("PURPA") has been, and continues to be, a net benefit for the natural gas industry. The gas industry should only support amendments to, or repeal of, PURPA if other statutory or [...] Read More

Profile of Underground Natural Gas Storage Facilities and Market Hubs

Introduction New underground natural gas storage and market center hubs have been among the most dynamic aspects of the evolving North American natural gas markets. These developments stem fiom the impacts of FERC Order No. 636, which potentially [...] Read More

Roundtable on Pipeline Construction Methods at River and Stream Crossings September 8

At the 91茄子 Foundation's Midyear Meeting, it was decided to sponsor a roundtable to discuss the scope of a study which would review the increasing stringent requirements for stream and river crossing permits. The goal was to assess the overall [...] Read More

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Standards of Conduct 91茄子 Reply Comments 4-30-07

Pursuant to the Notice of Proposed Rulemaking (“NOPR”) issued by the Federal Energy Regulatory Commission (“FERC” or “Commission”) on January 18, 2007, as modified by order dated February 28, 2007, the Interstate Natural Gas Association [...] Read More

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Form 2 91茄子 Reply Comments 4-27-07

The Commission's financial forms perform an important function by providing the Commission and the industry with a snapshot of the financial position of an interstate pipeline during the reporting period.  As they are currently designed, [...] Read More

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Capacity Release 91茄子 Comments 4-11-07

91茄子 submitted a response to questions posed by the Commission, along with comments on the petition for rulemaking to remove the cap on released capacity filed by Pacific Gas and Electric Company (PG&E) and Southwest Gas Company in RM06-21, and [...] Read More

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Standards of Conduct Initial Comments of 91茄子 3-30-07

91茄子 comments are in response to FERC's Notice of Proposed Rulemaking to establish new permanent affiliate regulations.  91茄子 requests that the Commission issue a Final Rule in this docket consistent with the following comments: 1.The [...] Read More

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Form 2 Initial Comments of the 91茄子 3-28-07

Pursuant to the Commission's “Notice of Inquiry” into the need for changes or revisions to its reporting requirements for financial forms issued February 15, 2007, submits comments principally directed at the Commission's Form Nos. 2 and 2-A, [...] Read More

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Standards of Conduct Motion for Exention of Time 2-27-07

The Associations, on behalf of their respective members, submit a Motion to extend the period for filing initial comments for an additional 15 days until March 30, 2007, and to extend the period for filing reply comments for an additional 10 days [...] Read More

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Section 1813 Native American Land Rights-of-Way Comments on Draft Report to Congress 5-2-07

91茄子 submitted comments to the Bureau of Indian Affairs, urging that the US Department of Energy and US Department of the Interior (Departments) Draft Report to Congress required by section 1813 of the Energy Policy Act of 2005 continues to [...] Read More

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Standards of Conduct Request for Expedited Clarification of 91茄子 2-2-07

91茄子 requests clarification or, in the alternative, rehearing of the FERC’s (Commission) Interim Rule issued on January 9, 2007.  The Interim Rule represents the Commission’s interim response to the decision of the United States Court of [...] Read More

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HIOS/Petal Gas Storage Reply Brief of Intervenor 91茄子 in Support of Petitioners 2-15-07

91茄子 filed an intervener’s reply brief in the HIOS/Petal litigation in the Court of Appeals for the DC Circuit. 91茄子 argues that FERC’s new rate of return policy, by basing pipeline returns on the returns earned by lower-risk LDCs, disregards [...] Read More

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HIOS/Petal Gas Storage Initial Brief of Intervenor 91茄子 in Support of Petitioners

91茄子 argues that FERC departed from precedent in permitting use of lower-risk LDCs in the proxy group for setting Petitioners’ rates, and arbitrarily foreclosed use of gas pipeline MLPs as proxies for determining a gas pipeline’s rate of [...] Read More

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Standards of Conduct 91茄子 Request for Rehearing 12-29-03

While 91茄子 recognizes that the Commission has made efforts to meet certain of the objections raised by the industry in comments on the Commission’s Notice of Proposed Rulemaking (“NOPR”) in this matter, the Final Rule adopted by the [...] Read More

Santa Letter to Kelliher Regarding Waivers of the Blanket Certificate Regulations

Chairman Joseph T. Kelliher Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Re: Docket No. EM06-5-000   Dear Chairman Kelliher: On November 22, 2005, I wrote to express the appreciation of the members of the [...] Read More

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Standards for Business Practices 91茄子 Comments 12-18-06

Standards for Business Practices for Interstate Natural Gas Pipelines and Standards for Business Practices for PubliPursuant to the Notice of Proposed Rulemaking issued October 25, 2006, 91茄子 submits the following comments on the Commission’s [...] Read More

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Audit Matters 91茄子 Reply Comments 12-9-05

Pursuant to the Commission's orders of October 20 and November 30, 2005, 91茄子 submits the following comments in reply to several of the comments filed in this proceeding on November 22, [...] Read More

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5 Income Tax Allowance Extension Motion

Pursuant to Rules 212 and 2008 of the Federal Energy Regulatory Commission’s (Commission) Rules of Practice and Procedure, 18 C.F.R §§ 385.212 and 385.2008 (2001), the Association of Oil Pipe Lines (AOPL), Interstate Natural Gas [...] Read More

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Audit Matters 91茄子 Extension Motion 11-29-05

91茄子 respectfully requests that the Commission grant this motion to extend the deadline for filing reply comments in this proceeding to December 9, [...] Read More

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Income Tax Allowances 91茄子 Comments 11-26-05

91茄子 offers these comments in response to FERC's Request For Comments (“Request”), issued December 2, 2004, in Docket No. PL05-5-000. 91茄子 is a national, non-profit trade association that represents virtually all of the major interstate [...] Read More